Inappropriate benchmarking is the greatest area of dispute between DCAA and contractors. For example, under the geographic area, DCAA may compare national data when contractors believe more regional data needs to be compared or regional data may be examined (e.g. West Coast) by DCAA where contractors feel unique areas need to be examined (e.g. Silicon Valley). Size criteria often becomes quite contentious because there may not be enough distinction by the government of company size where contractors feel surveys are often very imprecise in terms of focusing on relevant size. For example, absence of survey data for smaller firms resulted in auditors inappropriately taking data from one size firm (e.g. smallest firms in the survey were $20 million of revenue) and projecting on a linear curve benchmark data for a different size organization (e.g. $1 million revenue). Under industry criteria disputes arise because most survey track large industry groups and do not distinguish between significant sub-industry groupings. For example, in the case of non-profit organizations, we have often seen DCAA use a survey tracking "non-profits" that make no distinction between social services and technology transfer organizations that must hire highly skilled high tech veterans.

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