Comprehensive Labor Audit
for Fiscal Year 2004
March 2005
Reference
Number: 2005-1C-044
This
report has cleared the Treasury Inspector General for Tax Administration
disclosure review process and information determined to be restricted from
public release has been redacted from this document.
March 29, 2005
MEMORANDUM FOR DAVID A. GRANT
DIRECTOR OF PROCUREMENT
INTERNAL REVENUE SERVICE
FROM: Daniel R. Devlin /s/ Daniel R. Devlin
Assistant Inspector General
for Audit (Headquarters Operations and
Exempt Organizations Programs)
SUBJECT: Comprehensive Labor Audit for Fiscal Year
2004 (Audit #20051C0209)
The
Defense Contract Audit Agency (DCAA) examined the Civil Division’s labor cost
charging and allocation system to evaluate the adequacy of and the contractor’s
compliance with the system’s internal controls for recording and accumulating
labor charges.
The
DCAA considers the contractor’s labor recording system to be inadequate in part. The DCAA examination of the Civil Division’s labor
and billing practices for Time and Material subcontractors noted a significant
deficiency. According to the DCAA, the
contractor’s practice does not include a reconciliation of the subcontractor’s
official labor hour records to the amounts recorded in the contractor’s
internal system of recording subcontractor labor hours (the Subcontractor
Information Management System (SIMS)) until the end of the contract. According to the DCAA, externally generated
documents prepared by the subcontractor, not the contractor’s internally
generated document from the SIMS, are the official source for recorded
subcontract costs. Additionally, the
DCCA opined that the contractor’s current practice of waiting until contract
completion to perform this reconciliation significantly reduces the ability of
the contractor, the subcontractor, and the Federal Government to evaluate any
discrepancies in the recorded subcontract hours. This could result in significant overpayments
of labor costs.
Specifically,
the DCAA indicated the following deficiencies: subcontractor official labor records are not
reconciled to the contractor’s internal SIMS; the Time and Expense Schedule is not
completed daily; employee location rosters are not current; and employees are not
obtaining a telework agreement prior to working at home.
The DCAA took no exception to the contractor’s using the SIMS
for interim billing of subcontract labor costs.
However, the DCAA believes the contractor should (1) require the
subcontractors to periodically submit interim invoices in accordance with
Federal Acquisition Regulation 4-705 and the Civil Division’s Subcontract
Agreements, (2) periodically reconcile these interim invoices to the hours
recorded in the contractor’s SIMS during the course of contract performance,
and
(3) adjust billings accordingly. All contractor employees should adhere to the
established Timekeeping and Reporting Handbook and record their hours worked on
a daily basis, and the contractor should maintain updated employee location
information and properly inform all its employees of the policy and procedures
for performing work at home. Also, the
contractor should document its training to ensure all employees are familiar
with its policies and procedures, have attended the training on this subject,
and adhere to established policies and procedures.
This
DCAA report was issued on June 2, 2004; however, the Treasury Inspector General
for Tax Administration (TIGTA) did not receive copy of the report until February
2005. The Internal Revenue Service (IRS)
previously received a copy of the report directly from the DCAA. We are transmitting this report to you to
enable the IRS to track any financial accomplishments derived from negotiations
with the contractor based on the results of this DCAA report.
The
information in this report should not be used for purposes other than those
intended without prior consultation with the TIGTA regarding their
applicability.
If you have any questions, please
contact me at (202) 622-8500 or John R. Wright, Director, at (202) 927-7077.
Attachment
NOTICE:
The Office of Inspector General for Tax Administration has
no objection to the release of this report, at the discretion of the
contracting officer, to duly authorized representatives of the contractor.
The contractor information contained in this report is
proprietary information. The
restrictions of 18 U.S.C. § 1905 must be followed in
releasing any information to the public.
This report may not be released without the approval of
this office, except to an agency requesting the report for use in negotiating
or administering a contract with the contractor.
The TIGTA seal was removed due to its size.