Does PGI 215-404.2(c) (1) or (2) threshold dollar limits apply to DCAA audits to non-DoD contract proposals, or does the PGI apply only to DoD. In other words, can/must DCAA perform a proposal audit of a fixed price proposal below the $10 million threshold if requested by a non-DoD agency for a non-DoD proposal? Similarly, can/must DCAA perform an audit of a cost-type non-DoD proposal if requested and the proposal is less than $100 million?
The PGI (Procedures, Guidance, and Information) is a companion resource to the DFARS and contains internal DoD procedures and guidance for contracting personnel. So, it seems that only to the extent that the action requested involves DoD personnel and their actions would the PGI be controlling. Further, it might be worth noting that PGI 215.404-2(c) does not absolutely bar contracting personnel from seeking a DCAA audit in all cases where the proposal does not exceed the stated threshold amounts, but rather simply requires “exceptional circumstances”: “(ii) The contracting officer should not request DCAA audit assistance for proposed contracts or modifications in an amount less than that specified in paragraph (c )(I) of this subsection unless there are exceptional circumstances explained in the request for audit.”
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