Friday, July 31, 2015

When DCAA's Independence is Questioned

What happens after you complain to DCAA (Defense Contract Audit Agency) management about the actions of one of their auditors? We're not talking about disputes over access to records or difference of opinion on the allowability of a certain expense item. We're talking about attitudes, innuendos, some kind of bias, conflicts of interest, socializing with contractor employees, and other such actions that call into question an auditor's objectivity.

DCAA takes such complaints very seriously. To have such a complaint lodged speaks to DCAA's independence. Maintaining independence in audits (both in fact and in appearance) is critically important to DCAA's credibility and is required by GAGAS (Generally Accepted Government Auditing Standards). DCAA expects its auditors to always act professionally, objectively, and without bias when conducting audits and interacting with contractor personnel.

When a contractor makes a complaint about circumstances or behavior that indicate, or appear to indicate, auditor bias, it also means that there may be a threat to that auditor's independence. When that happens, and it does happen more often than one might suspect, DCAA management will make a initial judgment call as to whether there is any substance to the allegation. If there is sufficient basis for inquiry into the contractor's complaint, management will immediately notify and temporarily remove the auditor from the affected audit(s).

If, based on the inquiry, DCAA management finds that no significant threat to independence exists and that the auditor's independence has not been impaired, the temporary removal will be lifted and the auditor will return to duties as usual. However, if management determines that there is a significant threat to independence, the auditor's independence is impaired, either of mind or in appearance, management will take immediate action to reduce the threat to an acceptable level. This usually means the auditor will be reassigned.

The reality is that once a contractor allegation has been lodged and an auditor temporarily removed from an assignment, the well is already poisoned. That auditor can never go back and be effective because the auditor cannot be objective any longer. That part is human nature. The auditor might go back in with a vengeance to "get even" or conversely, as a spineless milk toast afraid of the contractor's reaction. Either way, independence is compromised.

Contractors deserve impartial, independent, and objective audits and should be cognizant of, and report on, situations where an auditor's independence and objectivity is questionable.

Source: DCAA Contract Audit Manual (DCAAM) 1-509.

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