Chapter 7-2105 of the DCAA Contract Audit Manual (DCAM) provides insight into areas of particular concern when professional services costs are being audited. In addition to reiterating FAR requirements, auditors are told to:

(1) Ensure other unallowable costs (e.g. political donations, bribes) are not included in this category of expense

(2) Though auditors are told not to substitute their judgment for explicit documentation requirements (e.g. agreement details, invoices and work products) they are told to use their judgments to determine if documentation is adequate.

(3) Where auditors used to commonly disallow costs if "work product" was not deemed adequate, new guidance significantly changes the work product criteria where "other evidence may suffice" to determine the nature and scope of work performed.

(4) The burden of producing adequate evidential matter to support claimed costs falls on the contractor. If additional support is needed, the auditor is told to ask for it and give the contractor a reasonable time to comply after which if not provided, the costs are to be questioned as "expressly unallowable" in accordance with FAR 31.205-33(f). (Editor’s Note. The term expressly unallowable is normally meant to be a green light to recommend imposition of penalties up to three times the questioned amount.)