Defense Contracting:

DOD Initiative to Address Audit Backlog Shows Promise, but Additional Management Attention Needed to Close Aging Contracts

GAO-13-131: Published: Dec 18, 2012. Publicly Released: Dec 18, 2012.

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(202) 512-4841
dinapolit@gao.gov

 

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What GAO Found

To reduce the backlog of incurred cost audits, the Defense Contract Audit Agency (DCAA) implemented an initiative to focus its resources on auditing contractors' incurred costs that involve high dollar values or are otherwise determined to be high risk. Incurred cost audits are conducted on a contractor's annual proposal that includes all costs incurred on certain types of contracts in that fiscal year. Under the initiative, DCAA raised the dollar threshold that triggers an automatic audit on a contractor's incurred cost proposal from $15 million to $250 million, revised the criteria used to determine a proposal's risk level, and significantly reduced the number of low risk audits that will be randomly sampled. This initiative appears promising, and DCAA plans to track certain characteristics, such as the number of risk determinations made and audits completed. But DCAA has not fully developed the measures by which it will assess whether the initiative reduces the backlog in a manner that protects the taxpayers' interests. Specifically, DCAA does not have a plan for how it will determine whether key features of the initiative, such as the revised risk criteria and the revised sampling percentages, should be adjusted in the future. By 2016, DCAA estimates it will reduce the backlog and reach a steady state of audits, which it defines as two fiscal years of proposals awaiting review. DCAA's ability to achieve this goal will depend on a number of factors, including the number of proposals determined to be high risk, which as of September 2012 was about two-and-a-half times more than anticipated.

Reducing the backlog of incurred cost audits will ease one obstacle to closing over-age contracts, but other obstacles, such as limited data and performance metrics, must still be overcome. The military departments have limited data on the extent and nature of their contract closeout backlog, and the Defense Contract Management Agency (DCMA)--which performs contract administration services for the Department of Defense (DOD)--is missing information that would allow it to identify contracts that it could act on. Such data can cue agencies on how to identify or tailor approaches to address the backlog. Further, the military departments generally do not have performance metrics to measure progress in closing out contracts. The Army recently announced a goal of closing over 475,000 contracts by September 2014; however, it does not yet have the information necessary to know if it can reach this goal and does not have an implementation plan. The Navy and the Air Force had not established any department-wide performance metrics for contract closeout. In contrast, DCMA has established two agency-wide performance metrics related to contract closeout that are regularly monitored. While many officials said contract closeout was not a priority, GAO found some local contracting activities taking action to bring attention to contract closeout.

Why GAO Did This Study

DOD has a large volume of contracts that have not been closed on time. Closing a contract includes tasks such as verifying that the goods and services were provided and making final payment to the contractor. Closing contracts within required time frames can limit the government’s exposure to certain financial risks. One reason why some contracts are not being closed is the large backlog of incurred cost audits that must first be completed. These audits, conducted by DCAA, ensure that the costs contractors have incurred are permissible under government regulations.

The Senate Armed Services Committee report accompanying the National Defense Authorization Act for Fiscal Year 2012 directed GAO to review the criteria and procedures for conducting incurred cost audits, among other things. In response, GAO assessed (1) efforts to reduce the backlog of incurred cost audits and (2) the challenges DOD faces in addressing the contract closeout backlog. GAO reviewed DCAA’s policies and procedures for incurred cost audits; analyzed data on the audit and contract closeout backlogs; and interviewed officials in the military departments and agencies.

What GAO Recommends

GAO is recommending that DCAA develop a plan to assess its incurred cost audit initiative; that DCMA improve data on over-age contracts; and that the military departments develop contract closeout data and establish performance measures. DOD concurred with the recommendations and identified ongoing and planned actions to address them.

For more information, contact Timothy J. DiNapoli, (202) 512-4841or dinapolit@gao.gov.

Status Legend:

More Info
  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: To improve DCAA's ability to assess whether its incurred cost backlog initiative is achieving the objectives of reducing the incurred cost audit backlog while continuing to protect the taxpayer's interests, the Director, DCAA, should develop a plan that includes time frames and measures to assess progress towards achieving its objectives, and as appropriate, to identify how it will assess whether the changes in DCAA's procedures and criteria are appropriate or require further revisions.

    Agency Affected: Department of Defense: Defense Contract Management Agency

    Status: Open

    Comments: DCAA has taken some steps to address this recommendation. DCAA has developed a monitoring plan that includes measures and some timeframes for assessing its incurred cost audit backlog initiative, and this plan includes identifying how the agency will assess whether changes in the initiative's procedures and criteria are needed. For example, DCAA's monitoring plan states that DCAA will analyze its high risk determinations and audit results to determine if some criteria for determining the risk level of an incurred cost audit proposal are better indicators of risk than others, and to adjust its risk criteria accordingly. DCAA's monitoring plan states that the results of this analysis will be included in a monthly report. While the monthly report is identified as the timeframe for some of the measures in the monitoring plan, not all of the measures have timeframes identified. Further, the monitoring plan has yet to be executed, and, according to a DCAA official, may require some refinements once implemented.

    Recommendation: To increase visibility and enhance management attention on closing out contracts within their departments, the Secretaries of the Navy and Air Force should, respectively, develop baseline data and performance measures for closing out contracts, including consideration of the use of quick closeout procedures, as appropriate.

    Agency Affected: Department of Defense: Department of the Navy

    Status: Open

    Comments: The Department of the Navy has taken some steps to address this recommendation, but additional actions are needed. On July 8, 2013, the Department of the Navy's Office of the Assistant Secretary for Research, Development, and Acquisition issued a memorandum to its commands requesting that contracting officers remain diligent in closing out contracts within the timeframes required by the federal acquisition regulation, and asking for the commands to provide their internal policies and procedures on closing out contracts. This memo demonstrates enhanced management attention on closing out contracts, however, to fully address the recommendation, the Navy needs to develop baseline data and performance measures for closing out contracts, including the use of quick closeout procedures as appropriate.

    Recommendation: To increase visibility and enhance management attention on closing out contracts within their departments, the Secretaries of the Navy and Air Force should, respectively, develop baseline data and performance measures for closing out contracts, including consideration of the use of quick closeout procedures, as appropriate.

    Agency Affected: Department of Defense: Department of the Air Force

    Status: Open

    Comments: The Air Force had not provided any information on actions taken in response to this recommendation.

    Recommendation: To facilitate the closeout of contracts within the Army, the Secretary of the Army should ensure that the Army's contract closeout implementation plan includes baseline data and performance measures, and includes consideration of the use of quick closeout procedures, as appropriate.

    Agency Affected: Department of Defense: Department of the Army

    Status: Open

    Comments: The Department of the Army has taken steps towards addressing this recommendation. The Office of the Deputy Assistant Secretary of the Army (Procurement) established a contract closeout task force and identified a baseline of 377,160 contracts to be closed (this baseline was revised downward from the estimated 475,000 overage contracts the Army had reported at the time of our review). The Army has also established goals for when these overage contracts should be closed. For example, the taskforce has the goal of closing half of the baseline overage contracts by October 2013, and all of these contracts by September 2014. In addition to establishing goals for closing the initial baseline of overage contracts, the Army is monitoring newly overage contracts. The Army has also drafted a template for its commands to track the number of overage contracts, goals for closing these contracts, and actual contracts closed, among other things. However, according to an Army official, this template has yet to be implemented. In addition to these actions, an Army official reports that the contract closeout taskforce continues to explore a number of efforts to improve its closeout processes and procedures going forward, such as electronic closeout and creating incentives in the Army Ordering Guide Procedures for timely closeout (e.g., offering lower fees on a subsequent order if the previous order was closed out on time).

    Recommendation: To enable DCMA to better identify contracts that may be closed out, the Director, DCMA, should take steps to ensure the data in DCMA's contract information system on who has responsibility for moving the contract forward in the closeout process is complete.

    Agency Affected: Department of Defense: Defense Contract Management Agency

    Status: Open

    Comments: DCMA has taken some steps to address this recommendation, but more needs to be done. DCMA reported that the agency has a mechanism for querying its database to identify who has responsibility for moving the contract forward in the closeout process. However, at the current time, the report developed from this query cannot link the information of who is responsible for moving the contract forward to the stage in the closeout process where the contract is currently held up. Without this linkage, DCMA does not have the information it needs to effectively identify where and why overage contracts are held up in the closeout process, which could enable them to develop solutions for moving these contracts forward. DCMA told us it is taking steps to update the report to add the information on where the contract is in the closeout process.

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