Report on Noncompliance With Cost Accounting Standard 410, Allocation of
Business Unit General Administrative Expenses to Final Cost Objectives
March 2005
Reference
Number: 2005-1C-045
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: Report on Noncompliance With Cost
Accounting Standard 410, Allocation of Business Unit General Administrative
Expenses to Final Cost Objectives (Audit #20051C0210)
The
Defense Contract Audit Agency (DCAA) performed an examination regarding the
contractor’s compliance with Cost Accounting Standards (CAS) and the Federal
Acquisition Regulation (FAR). The
purpose of the examination was to determine whether the contractor complied
with the requirements of CAS 410 (Allocation of Business Unit General
Administrative Expenses to Final Cost Objectives).
The
DCAA stated that, during the period April 1, 2003, through March 31, 2004, the
contractor was in noncompliance with CAS 410 and the FAR. The DCAA also noted that, as of the date of its
report, the condition causing the noncompliance had not been corrected. According to the DCAA, its report is limited
to the cited instance of noncompliance.
Accordingly, the DCAA expresses no opinion on whether other practices
are proper, approved, or agreed to for pricing proposals, accumulating costs,
or reporting contractor performance data.
However, the DCAA examination disclosed that the contractor’s failure to
comply with CAS 410 and failure to consistently follow its disclosed accounting
practices resulted or may result in increased costs paid by the Federal Government.
The
areas of noncompliance and failure to follow disclosed practices are:
·
Material costs (purchased parts, service charges, and
interdivisional transfer costs) are improperly included in the value-added General
and Administrative (G&A) base.
·
The Civil Division CAS disclosure statement, effective March
29, 2003, states the G&A base is comprised of total costs incurred less the
costs of purchased parts and services, raw material, interdivisional transfer,
and other categories.
As
a result, the DCAA considers the contractor’s actual practices of accumulating
or reporting costs to be in noncompliance with its Disclosure Statement because
material costs and interdivisional transfer costs should be excluded from the
G&A base. Additionally, because of this
inconsistent practice, the contractor is not complying with FAR 52.230-2(a)(2). This clause also requires that, if any change
is made to those practices, the Disclosure Statement must be amended.
During
the review, the DCAA requested the contractor to estimate the magnitude of this
noncompliance. The contractor responded
that costs of approximately $1.6 million (0.54 percent of the $299 million
G&A base) were erroneously included in the G&A base, resulting in a
0.06 percent impact on the G&A rate.
The
DCAA recommends that the contractor establish and maintain a consistent,
current, accurate, and complete description of all cost accounting practices
which affect Federal Government contracts and follow the practices outlined in the
Civil Division Disclosure Statement, effective March 29, 2003, concerning the
G&A base. The DCAA also stated the
contractor should remove the material costs (equipment maintenance/repair,
equipment maintenance supplies, etc.) and interdivisional transfer costs from the
G&A base. Additionally, the contractor
should comply with CAS 9904.
This
DCAA report was issued on June 16, 2004; however, the Treasury Inspector
General for Tax Administration (TIGTA) and the Internal Revenue Service (IRS) did
not receive a copy of the report until February 2005. 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.