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  • Question

    Is the use of the wording "findings and/or results" intended to mean the same term.


    Answer

    Yes, the word finding and results refer to the same meaning under the context of an audit, self-assessment, analysis, etc.; however, the FAR uses the term “significant finding” to separately identify the type of results, which can make things a bit confusing.  Merriam Webster Dictionary defines finding as – A result reached after an examination or investigation by an administrative body or officer.  The word significant is a term used to identify the level of impact/risk of a negative finding.  Are all findings negative? Thankfully… NO they are not.  In auditing, a finding is merely the result of an evaluation, analysis or an audit, based on audit evidence. Those “results” can be either positive or negative. 

    You made some great observations within the body of your background that I would also like to clarify. The 2007 FAR 52.245-1 (f) (3) requires the contractor to perform periodic internal reviews and audits.  Additionally, with the understanding that the word finding can be both positive and negative; it requires the contractor to make available to the property administrator any findings, obtained in an internal assessment relating to Government Property.  When the 2012 update was issued it clarified the requirement by removing “and/or” and replacing it with “and.”  The requirement was also moved from paragraph (f) to paragraph (b) Property Management. I have included both versions below for your convenience.
     
    The Contractor’s requirement for reporting audits and self- assessments falls under FAR 52.245-1 (f) (1) (vi): Reports. The Contractor shall have a process to create and provide reports of discrepancies; loss, damage, destruction, or theft; physical inventory results; audits and self-assessments; corrective actions; and other property related reports as directed by the Contracting Officer.
     
    The contractor must identify within their procedures how they will provide the results; e.g., at the Property Administrators (PAs) request, only significant findings within 10 days of the final results, etc.  FAR 45.105 obligates the contract administration agency (the PA) with the responsibility of conducting an analysis of the contractor’s property management policies, procedures, practices, and systems. This includes self-assessments since they are a requirement within the Contractors Property Management System. It is important for PAs to understand how the Contractor performs their self-assessments (methodology) as well as be aware of all results, both positive and negative since risk assessment determinations are based on the findings/results of all system audits performed by both the Government and the Contractor.  For example, if the Contractors audit processes are equivalent to the Government auditing standards the PAs can sometimes expand on an identified risk area or even waive outcomes based on self-assessment/audit results. Most importantly PAs need to be aware of property management system alterations which can be prompted by both positive and negative results identified in a self-assessment.
     
    (2007) FAR 52.245-1 (f) (3) Contractor Plans and Systems. The Contractor shall establish and maintain procedures necessary to assess its property management system effectiveness, and shall perform periodic internal reviews and audits. Significant findings and/or results of such reviews and audits pertaining to Government property shall be made available to the Property Administrator.
    (2012) FAR 52.245-1(b) (4) Property Management. The Contractor shall establish and maintain procedures necessary to assess its property management system effectiveness and shall perform periodic internal reviews, surveillances, self-assessments, or audits. Significant findings or results of such reviews and audits pertaining to Government property shall be made available to the Property Administrator.

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