Can a DCAA audit be waived if the Contracting Officer can determine reasonableness based on labor being evaluated by a technical evaluator, utilizing FPRA and FPRR's, and utilizing purchase order history to evaluate the small amount of material? If so, what is the policy for doing so and what approval level is required for the waiver?
The Federal Acquisition Regulation (FAR)/ Defense Federal Acquisition Regulation Supplement (DFARS) do not require a contracting officer to obtain a Defense Contract Audit Agency (DCAA) audit as a prerequisite to negotiating the price of a prospective contract. Therefore, no waiver or deviation from FAR/DFARS requirements are compelled when no DCAA audit is sought. This is not to say that your local policy and procedure, whatever that may be, does or does not provide audit request procedures that you should also consider. In fact, you may find it very reasonable to consult local policy and procedures as well. This is also not to say that if the contracting officer needs a DCAA audit to determine proposed prices fair and reasonable that he/she should not seek an audit, because she/he should.
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FAR 15.404-2 assigns the contracting officer responsibility for determining the extent of all field pricing support required, including the need, or not, for DCAA audit support. Generally speaking and in summary, the FAR calls for the contracting officer to “request field pricing assistance when the information available at the buying activity is inadequate to determine a fair and reasonable price.” (see FAR 15.404-2 (a)(1), et al ). In addition, Department of Defense (DoD) acquisition personnel should also be cognizant of the Procedures, Guidance, and Information (PGI), a companion resource to the DFARS that contains both mandatory internal DoD procedures and non-mandatory internal DoD procedures and guidance. More specifically, PGI 215.404-2 identifies in some detail procedures and guidance regarding contracting officer requests for field pricing support and audit assistance.