Notification of Major System Changes - Policy
Contents |
Process Owner
Senior Executive of Corporate Compliance
Purpose
This document establishes the requirement and assigns responsibility to provide advance notification to the Federal Government in order that major system changes or additions can be validated prior to their implementation.
Definitions
ACO – Administrative Contracting Officer – a person in the employ of the Federal Government with the authority to enter into, administer, and/or terminate contracts; and make related findings and determinations.
CAS – Cost Accounting Standards - The Cost Accounting Standards provide rules for estimating, accumulating and reporting costs under negotiated government contracts and subcontracts over $750,000. There are presently 19 cost accounting standards that a fully CAS compliant contractor must follow.
DCAA - Defense Contract Audit Agency - This agency was established by the Federal Government for the purpose of performing all contract auditing for the Department of Defense (DoD) and providing accounting and financial advisory services, in connection with the negotiation, administration and settlement of contracts and subcontracts, to all DoD procurement and contract administration activities. DCAA also furnishes contract audit service to other Federal Government agencies.
FAR – Federal Acquisition Regulation – provides uniform policies and procedures for acquisitions by executive agencies of the Federal Government. Government contractors must abide by the FAR.
Validation – to substantiate; or to give official sanction, confirmation, or approval to; such as validation of the documents, or validation of the process.
Major Business Systems
- Accounting System
- Cost/Estimating System
- Contractor Purchasing System
- Earned Management System
- Material Management & Accounting System
- Contractor Property Management System
Policy
It is GovC’s policy to provide advance notification in writing to DCAA and/or a cognizant ACO whenever there is a planned cost accounting change or major system software implementation. The notification will need to provide sufficient time for government officials (e.g. DCAA) to determine if audit procedures need to be completed in order to evaluate whether the planned changes will impair current or updated system performance on FAR and CAS requirements.
Responsibilities
Corporate Compliance has lead responsibility to evaluate the nature of the planned cost accounting change or major system software implementation, and prepare and present the government official notification accordingly. The Corporate Compliance Department also has lead responsibility to coordinate performance of any audit procedures. Company Management responsibilities include the requirement to notify the Corporate Compliance Department of significant new system initiatives and process changes. Finance and Accounting management shall notify Corporate Compliance of any contemplated accounting changes.
