(Editor’s Note. It is quite common for auditors and government contracting personnel to refer to various guidelines issued by their agencies to support their positions. The following seeks to lessen this tendency and encourage government employees to rely on regulations rather than guidance to support their position. However, as consultants to contractors, w often find it advantageous to point out to auditors and CO representatives that their guidance supports specific contractor positions.)
Following recent criticism that the DOD’s new guidelines on accounting changes are being cited as law, Director of Defense Procurement Deidre Lee issued a memo September 10 stating guidance issued by its office (DPP) is to be applied by government contracting personnel in negotiating and administering government contracts but is not to be considered legally binding on contractors. When issues arise, contracting personnel are told to cite applicable regulatory references (e.g. FAR, Cost Accounting Standards) or specific contract clauses to support their position. This memo was included in recent DCAA guidance (MRD-02-PAC-070(R)) that stressed auditors should reference appropriate regulations when they formulate positions based on DPP guidance such as what constitutes an accounting practice change.
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