Friday, January 24, 2014

Evaluation of Final Vouchers

Once upon a time, DCAA (Defense Contract Audit Agency) performed audits, or least they called them audits, of final vouchers. Final vouchers are those documents submitted by contractors after contract completion and after the pertinent annual incurred cost audits have been completed. 

Back in 2009, the DoD Inspector General came along and decided that the procedures that DCAA was applying to reviews of final vouchers did not rise to the level of an "audit". Most notably, DCAA rarely tested any transactions during these reviews. Most of the activity involved reconciling the final voucher to incurred cost claims.

DCAA agreed and changed the name of the activity from Contract Audit Closing Statements (CACS) - whose name implied that an audit was performed, to "Evaluation of Final Voucher". Gone now is the wording found in the CACS that an audit was performed in accordance with Generally Accepted Government Auditing Standards (GAGAS). In its place, the scope more generally describes the tasks and comparisons performed.  

Those detailed steps, now called "non-audit" steps are basically comprised of reconciliations and comparisons. For most types of flexibly priced contracts, these steps include:

  1. Reconcile claimed direct costs by year to annual audit files
  2. Verify subcontract amounts agree with assist audits
  3. Verify that the final rates are those agreed upon
  4. Perform a math check
  5. Verify period of performance
  6. Determine whether fee is calculated correctly
  7. Verify that the total amount claimed does not exceed the lesser of the allowable costs or funding limitation.
If your final vouchers reconcile to your annual incurred cost submissions (as negotiated), the final voucher process should flow very smoothly. If they don't reconcile, be prepared to identify the reasons and rational for any differences. You're going to get asked anyway so you might as well be prepared.

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