CAM is Guidance, FAR is Rule

As a former DCAA auditor, I am still stunned at the level of trepidation experienced by contractors when the terms “audit”, “DCAA“, or “compliance” are mentioned.  The most surprising to me is that one agency can strike such fear into those they must deal with.

I always considered myself to be someone that could bridge the gap between expectations and reason.  I expected an audit to go easily.  I expected the auditee to have things ready for me when I got there or be able to get them for me in pretty quick order.  I expected that I would find something that I didn’t understand… and admit it to the contractor.

It was this last piece that I think really made me an auditor that was easy to work with.  I worked on a mobile team (auditable dollar values in the low millions and tens of millions of dollars), so I saw a lot of companies.  I did NOT know everything about every one of them, but I was willing to learn and have them walk me through.  It worked wonders.

A lot of time, I would sit down at an entrance conference and they would be walking me through what they did (the Excel sheet, Peachtree export, etc.) and why they did things a certain way and I could feel the tension in the room.  On one particular occasion I was feeling rather comfortable and just asked before I could stop the words from coming out.  “Are you scared of me?  If so, you don’t need to be.”  The answer was just as quick and caught me by surprise.  I was 3 years out of college and gaining a footing in the industry still – how could I be intimidating?!

DCAA CAM is guidanceAfter a long conversation about costs and auditors and the implication of compliance problems and unallowable costs, I mentioned that we use the DCAA Contract Audit Manual (CAM) as the guidance to complete our audit and that I have some latitude in making judgments as I go…

Surprise filled the room.

As many times as DCAA auditors are directed that CAM is guidance, some still use it as a defense or a crutch.  As I transitioned out of the agency, I noticed it more and more in professional activities.  FAR (and DFARS) is the regulation for contracting and making the call on allowability.  The guidance of the CAM is meant only to give the auditor a way of performing the work – a “best practice example” of sorts.

I mention all of this now because of the scrutiny that all agencies are undergoing.  I am still a big cheerleader for DCAA and the opportunity it provides to the new auditing professional, but I also know the agency has seen its share of troubles.  As it continues to get its teeth back and go forward, I just wanted to pause and remind everyone the auditors can be reasonable – some may not know it (or long since forgotten), so feel free to bring it to their attention.

About Marty Herbert

With 13 years of government contract administration, analysis, finance, and audit experience, I have established a firm baseline in ethics and a specialization in government contracts that has prepared me to become a subject matter expert in my field. I am currently working on enhancing government contracts management and compliance through workflow tools and product offerings - attempting to make the process proactive as opposed to reactive.
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2 Responses to CAM is Guidance, FAR is Rule

  1. C. David Buchanan says:

    I do not want to seem flip or disrespectful. I readily admit more than some frustration. “I am just sharing my insight from a personal experience on this one.”
    The answer to the question “Are you scared of me?” is well supported within the blog post.
    Someone with little experience, attempting to gain a footing in “the industry”, who knows little if anything about my industry, product, or customer; is about to take a couple a thousand pages of “guidance” in applying several thousand pages of regulation, to what took several thousand labor hours to produce within a too short calendar time. Any detail this person fails to come to understand within a week represents “Unsupported Cost”. As a result my fellow teammates and I may well be out of a job, while the Government worker happily moves on to gain an additional foothold, one rung higher in “the industry” that seems to value subjugation over service to the warfighter.
    Yes, you scare the life right out of me.

  2. I feel your frustration. I was new on the job when these things happened and have now felt the same “wrath” that you have seen. I am glad you “enjoyed” the story. My hope is that more challenges and less fear comes out of it. In the end, DCAA can make recommendations, but they are not the law.


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