Monday, January 23, 2012

Proposal to Streamline Submission of Interim Vouchers

The Department of Defense is proposing to make a significant revision to its procedures for processing interim vouchers by taking away the Defense Contract Audit Agency's (DCAA's) authority to approve contractors for direct billing. Under current regulations (DoD FAR Supplement 242.803), DCAA can authorize contractors to directly submit their vouchers for provisional payment to the disbursing office when DCAA is satisfied that the contractor's billing system is adequate. For contractors without approved billing systems, interim vouchers must first go through DCAA for review and approval. Contractors that are able to submit interim vouchers directly Government paying offices, can often significantly reduce the cycle time between voucher submission and payment and that means faster cash flows.

Under the proposal published January 19, 2012, every contractor is automatically approved for direct billing. DCAA has no say in the matter. The only interim vouchers that DCAA can review prior to payment are those "selected using sampling methodologies". This proposal represents a significant diminution of DCAA's authority and responsibility and is yet another example of how DoD is systematically dismantling its auditing arm or, as some have called "its first line of defense" against contract irregularities.

You can read the entire proposal here.

Any comments received by March 19, 2012 will be consider in the formation of the final rule.

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