Recent DCAA guidance moves the possibility of subcontractor audit to an annual function as opposed to a onetime “contract life” practice.
“Subcontract assist audits will no longer be requested for the life of the subcontract; instead, auditors will evaluate risk every year and request subcontract assist audits as needed. We are revising guidance because of the sensitivity of subcontract awards and changes within the contract administration and contract audit environment (e.g., contract closeout, low risk memorandums). The revisions and clarifications to CAM 6-802.5 and the 10100 Post Year-End Incurred Cost Audit Program also incorporate suggestions from the field and stress the importance of clear communication between prime and subcontract auditors.”
This is on top of the recent pressure to audit subcontractors based on the subcontractors costs and the recent directive to DCMA to audit all contractors for cyber security issues via Business System Audits.