presented by: pam gouldsberry, contracts group chief corlee brown, aco linda rowe, aco shirley...
TRANSCRIPT
Presented By:
Pam Gouldsberry, Contracts Group ChiefCorlee Brown, ACOLinda Rowe, ACOShirley Leonard, ACO
Risk-Based Initiative for Contract Closeout:
One CMO’s Perspective
2
Agenda
• Background – DCMA VA
• Closeout Overview from DCMA VA Perspective
• T&M Initiative
• Alternative Closeout Approaches– High Risk Contractor
– Anteon Closeout Initiative
3
Background – DCMA VA
Challenges: Unique Situation
WorkloadStaffingPrioritiesAggressive Goals
4
From Physical Completion to Closed
Final Incurred Cost Proposal Due
6 Months 4 Months
Final Voucher Due
0-12 Months
Contractor FY Ends
Physical Physical CompletionCompletion
Settlement of Final Rates
Varies
CLOSEDCLOSED
Industry
DCAA
DCMA
DFAS
Services
Process Payment of
Final Voucher
Review/Process Final Voucher
Varies due to circumstances12-24 Months
Audit of Final Incurred Cost Proposal Due
DCAA Actuals8 –12 months
Flexibly Priced Closeout Timeline
DCAA Actuals30 Days
OPRs
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Contract Closeout Key Players
ONE FOCUS
Achieving the Goal Together
Indu
stry
Indirect Cost Props Final Inv/Vchrs Pkg
Refund Checks
DFAS
Reconciliation
Final Payment
Additional Funding
Property Disposition
Replacement Funds
Acceptance
Services
Indirect Cost Audits
Final OH Rates
Subcontract Audit
FV Review
DC
AA
DC
MA
Coordinate all Closeout Actions
6
T&M Initiative
What is it?• Risk-Based Approach
• Utilize fixed labor rates• Accept provisional G&A rate
• Streamlines the Contract Closeout Process• Settlement of Rates not required • Abbreviated Final Voucher • Expedites payment and closeout
60% T&M Contracts
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T&M Initiative – Teaming for Success
• Contractor Participation
• DCMA/DCAA Kickoff meeting for initial low risk contractors
• Lack of individual contract audits is an incentive
• Communicate conflicting priorities (canceling funds, etc.)
DCAA
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T&M Initiative Process
• Selection of contractors for participation
• Performance of risk assessments
• Getting contractors to participate
• Timely submission of final vouchers
• Sampling of final vouchers
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DCAA Reduced audit effort on low risk
contractors
DCMA Reduced reconciliation effort allowing
ACO to focus on active work Prevents funds from canceling Contract closes within FAR mandated
timeframes
Contractor Abbreviated final voucher process
saving time and dollars Submit Final Voucher before Final Rate
Settlement
DCAA Reduced audit effort on low risk
contractors
DCMA Reduced reconciliation effort allowing
ACO to focus on active work Prevents funds from canceling Contract closes within FAR mandated
timeframes
Contractor Abbreviated final voucher process
saving time and dollars Submit Final Voucher before Final Rate
Settlement
Benefits
Integrated Effort - DCMA, DCAA, ContractorsIntegrated Effort - DCMA, DCAA, Contractors
PartneringBusiness
Judgement
Risk
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Results!!!
• Contractors approved (low risk) 23/55
• High risk contractors (alternative approach) 4• Contracts closed
3,151
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High Risk Alternative Approach
• Background– Contractor Cooperative– Billing System Deficiencies– Significant G&A Costs Questioned in prior
audits– Contractor unable to generate sufficient
volume of final vouchers/monthly basis
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Overview of Risk-Based Process
– Identified 341 IDIQ Delivery Orders with rates settled
– DCAA determined increment/decrement factor for each IDIQ contract
– Unbilled amount< $50,000 contractor waived payment at Basic Level
– All credits were refunded to Government
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Benefits/Results
• Contractor – Reduced Final Voucher Preparation– Closeout Backlog Decreased
• Government– <60 days over 340 Delivery Orders closed
• Wynne Phase III contracts closed (app. 200)
– Replacement funds not required– Excess funds returned to Services
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Anteon Closeout Initiative
• Background– Low Risk Contractor– Multiple Acquisitions– Large Number of Overage Contracts with
Delinquent Final Vouchers
• Challenges– Close Large Number of Contracts (2,000+)– Meet Regulatory Requirements– Satisfy DCAA and DFAS Internal Operational
Requirements
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Anteon Closeout Initiative
• Process– MOA Between DCMA and Contractor– Agreement with DCAA and DFAS– Streamlined Submission Format– Accelerated Cumulative Allowable Cost
Worksheet (CACWS) Audit
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Anteon Closeout Initiative
• Submission Format– Use Spreadsheet Format (CACWS)– Group Like Vouchers (Credits, Debits, Zeros)– Streamlined Final Documents
• Form SF1034s, Releases, Assignment of Refunds, Rebates, and Credits)
– Deviation for Form DD 1597 (Closeout Worksheet)
– Concurrent Audit by DCAA
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Anteon Closeout Initiative
• Results– Final Vouchers with Documentation
• 2,056 Contracts• Provided by Contractor in 30 Days
– DCMA Reviewed 1,702 Final Vouchers– Currently in Payment Process
• 734 Contracts
– Closed 968 Contracts in 3 Months
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Questions