Open Recommendations

Rec 3.c1: The DoD OIG recommended that the Defense Contract Audit Agency Director in coordination with the Defense Logistics Agency Director, require non-Federal auditors to include in the quality control plan their planned procedures for complying withGovernment Auditing Standards, including Government Auditing Standards 7.14, "Investigations or Legal Proceedings."

Rec 3.c2: The DoD OIG recommended that the Defense Contract Audit Agency Director in coordination with the Defense Logistics Agency Director, require non-Federal auditors to include in the quality control plan their planned procedures for complying withGovernment Auditing Standards, including Government Auditing Standards 7.14, "Investigations or Legal Proceedings."

Rec 3.d1: The DoD OIG recommended that the Defense Contract Audit Agency Director in coordination with the Defense Logistics Agency Director, require non-Federal auditors to include in the quality control plan their planned procedures for complying withGovernment Auditing Standards, including Government Auditing Standards 7.34, "Examination Engagement Documentation."

Rec 3.d2: The DoD OIG recommended that the Defense Contract Audit Agency Director in coordination with the Defense Logistics Agency Director, require non-Federal auditors to include in the quality control plan their planned procedures for complying with Government Auditing Standards, including Government Auditing Standards 7.34, "Examination Engagement Documentation."

Rec 3.e1: The DoD OIG recommended that the Defense Contract Audit Agency Director, in coordination with the Defense Logistics Agency Director, require non-Federal auditors to include in the quality control plan their planned procedures for complying withGovernment Auditing Standards, including Standards for Attestation Engagements Number 18, section 205A.31, "Sampling."

Rec 3.e2: The DoD OIG recommended that the Defense Contract Audit Agency Director, in coordination with the Defense Logistics Agency Director, require non-Federal auditors to include in the quality control plan their planned procedures for complying withGovernment Auditing Standards, including Standards for Attestation Engagements Number 18, section 205A.31, "Sampling."

Rec 4.a: The DoD OIG recommended that the Defense Contract Audit Agency Director modify their quality assurance surveillance plan checklist to include a review of workpapers for compliance with Government Auditing Standards, including Government Auditing Standards 1.18a, "Examination."

Rec 4.b: The DoD OIG recommended that the Defense Contract Audit Agency Director modify their quality assurance surveillance plan checklist to include a review of workpapers for compliance with Government Auditing Standards, including

Rec 4.c: The DoD OIG recommended that the Defense Contract Audit Agency Director modify their quality assurance surveillance plan checklist to include a review of workpapers for compliance with Government Auditing Standards, including Government Auditing Standards 7.14, "Investigations or Legal Proceedings."

Rec 4.d: The DoD OIG recommended that the Defense Contract Audit Agency Director modify their quality assurance surveillance plan checklist to include a review of workpapers for compliance with Standards for Attestation Engagements Number 18, section 205A.31, "Sampling."

Rec 4.e: The DoD OIG recommended that the Defense Contract Audit Agency Director modify their quality assurance surveillance plan checklist to include a review of workpapers for compliance with Government Auditing Standards, including Standards for Attestation Engagements Number 18, section 205A.31, "Sampling."

(U) Rec 1: The DoD OIG recommended that the Commanding General, Army Contracting Command develop and implement procedures to establish realistic qualifying proposal due dates in definitization schedules, including considering size and complexity of requirements, historical time frames of the contractor providing proposals, and other programs requiring proposals from the same contractor.

(U) Rec 2: The DoD OIG recommended that the Commanding General, Army Contracting Command develop and implement procedures to update definitization schedule time frames when the Government makes changes to the original requirements, depending on the extent of changes.

(U) Rec 3: The DoD OIG recommended that the Commanding General, Army Contracting Command develop and implement procedures and provide training to contracting personnel on when to withhold payments from contractors that do not provide qualifying proposals in accordance with the definitization schedule.

(U) Rec 4: The DoD OIG recommended that the Commanding General, Army Contracting Command develop and implement procedures to ensure that contracting officers document, in the contract file, the justification for withholding payments or not withholding payments from contractors that do not provide qualifying proposals in accordance with the definitization schedule.

(U) Rec 5: The DoD OIG recommended that the Commanding General, Army Contracting Command develop and implement policy to standardize how contracting personnel establish and document in the contract file the beginning of the 180?day period to definitize.

(U) Rec 6: The DoD OIG recommended that the Commanding General, Army Contracting Command provide training to contracting personnel to clarify that the 180?day period to definitize the undefinitized contract action begins on the date the contractor submits the qualifying proposal, in accordance with the United States Code.

(U) Rec 7: The DoD OIG recommended that the Commanding General, Army Contracting Command develop and implement procedures to ensure that contracting personnel engage with the Defense Contract Audit Agency and Defense Contract Management Agency before obtaining contractor proposals when they determine that a Defense Contract Audit Agency or Defense Contract Management Agency audit will be required for the undefinitized contract action.

(U) Rec 8: The DoD OIG recommended that the Commanding General, Army Contracting Command develop and implement procedures to ensure that contracting personnel require contractors to submit Defense Federal Acquisition Regulation Supplement proposal adequacy checklists with proposals, in accordance with the Defense Federal Acquisition Regulation Supplement, and ensure contracting personnel review Defense Federal Acquisition Regulation Supplement proposal adequacy checklists to verify that proposals are adequate before submitting the proposals to the Defense Contract Audit Agency or Defense Contract Management Agency for their proposal audits.

(U) Rec 9: The DoD OIG recommended that the Commanding General, Army Contracting Command issue a memorandum requiring contracting personnel to request a waiver of the definitization schedule, when appropriate, and detailing the circumstances in which a waiver should be requested.

(U) Rec 10: The DoD OIG recommended that the Commanding General, Army Contracting Command develop and implement policy to establish meetings between contracting officials at each contracting activity and contractors on a regular and recurring basis to improve communication and determine responsibilities and impediments, along with a course of action for definitizing undefinitized contract actions within the 180?day requirement.

(U) Rec 11: The DoD OIG recommended that the Commanding General, Army Contracting Command develop and implement procedures and provide training to contracting personnel on how and when to unilaterally definitize undefinitized contract actions.

(U) Rec 12: The DoD OIG recommended that the Commanding General, Army Contracting Command issue a memorandum requiring contracting personnel to use the most current version of DD Form 1547, "Record of Weighted Guidelines Application," when completing weighted guidelines analysis on all negotiated undefinitized contract actions when certified cost or pricing date is obtained.

(U) Rec 13: The DoD OIG recommended that the Commanding General, Army Contracting Command develop and implement procedures to ensure that contracting officers assess the extent of incurred costs when definitizing undefinitized contract actions and prepare the DD Form 1547, "Record of Weighted Guidelines Application," including separating incurred costs from estimated costs to complete and applying separate risk factors based on the reduced cost risk to the contractor.

(U) Rec 14: The DoD OIG recommended that the Commanding General, Army Contracting Command Develop and implement procedures to ensure that contracting officers document their consideration of reduced cost risk during the undefinitized period and rationale for the assigned contract type risk values in price negotiation memorandums.