Friday, August 31, 2012

New DoD Rule for Approving Payment Requests

Last January, we wrote about the DoD proposal to streamline the Government's process for approving interim vouchers. We noted that "Streamlining" in this case was a euphemism  for effectively removing DCAA (Defense Contract Audit Agency) from the voucher processing business and allows all defense contractors to bypass the auditor when submitting payment requests, regardless of how that Agency views a contractor's billing practices and procedures. That proposal is now final.

Under the new rule, DCAA will use sampling methodologies to select interim vouchers for a prepayment review. All others will be "considered provisionally approved and will be sent directly to the disbursing office".

Under the old rule, DCAA could authorize contractors to directly submit their vouchers for provisional payment to the disbursing office when DCAA is satisfied that the contractors billing system was "adequate". Of course, it was almost impossible to get an "adequate" rating from DCAA so relatively few contractors qualified for direct billing. Under the new rules, everyone qualifies and the only exceptions are when vouchers are randomly selected for pre-payment reviews.

DCAA has yet to publish its sampling methodologies or specify what procedures will be performed in a pre-payment review. When we learn what those are, we will pass it along.

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