Most billing rejections are easy to fix. It might be as easy as changing a voucher number by one number. Perhaps it only requires a file upload to WAWF (Wide Area Work Flow). After fixing whatever it was that needed to be changed, contractors go about their business, ultimately get paid, and put the incident out of their minds.
While contractors might put such events out of their mind however, contract auditors are keeping track of such incidences. In the auditors' view, frequent billing errors may be indicative of systemic billing system deficiencies. It can be somewhat disconcerting for contractors to have three years of billing rejections dropped on them during a billing system audit and prodded for explanations. It may be impossible to explain; contractors do not usually retain and track such information, lack of employee continuity, and the perception that such events are inconsequential.
Sometimes auditors do not believe that anything is inconsequential. The standard audit program for contractor billing system audits contains the following procedure:
Review billings that were rejected by DCAA, other approving officials, and paying offices in order to identify trends and errors which are frequently repeated. Consider the trends and errors when designing the audit procedures to test contractor billings. If there are a significant number of errors (e.g., high percentage of rejected billings) this could be an indication of systemic problems. A deficiency report should be issued when sufficient evidence has been obtained and the auditor can demonstrate compliance with other GAGAS (e.g., adequate planning and supervision).Whenever a payment request is rejected, contractors should document the situation and preserve it somewhere within the billing system. That way, ready responses are available should anyone inquire.
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