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    So how does a contractor meet the criteria for a reportable audit (i.e. business system, ICP) when they don’t have any contracts to meet the criteria?


    Assuming the audit is from DCAA. I'm assuming that this is an incurred cost audit.   In the audit report, DCAA should have identified the contract(s) involved. If not, reach out to the auditors and ask.


    Several things  may have happened.

    1.      The contract may have been miscoded in the DCMA system.

    2.      the contract administration delegation could be incorrect.  

    3.      For there to be an incurred cost audit, there must have been an incurred cost submission and DCMA should have received the submission too.

    4.       At the beginning of the audit, DCAA should have reached out to the contracting officer and asked if there were issues or concerns that the auditor could include in the risk assessment. 

    5.      Sometimes fixed price contracts have reimbursable CLINs.  This reimbursable CLINS would be subject to an audit.


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