On April 9, 2013, the Defense Contract Audit Agency informed its auditors that it had implemented a new Instruction that streamlined the audit review process. Why did the existing audit review process need streamlining? In the words of the MRD—

… feedback from the field indicated it was taking too long, there were too many required levels of review (some of which were duplicative), and there were inconsistencies in the review process between Teams, FAOs, and Regions.

Yes.

Readers of this blog may recall that, from time to time, we’ve asserted much the same thing. We’ve blamed the audit review process for the lack of timeliness in issuing audit reports as well as the lack of transparency in the process. Once a report goes into the review cycle, the auditee (contractor) loses track of it and must simply wait for it to drop into the Contracting Officer’s mail queue, unexpectedly, like a meteor from the sky. We have personally witnessed reports disappearing into “management review” hell for two, three, or even more, years.

So it’s nice that DCAA leadership finally admitted that its review process needed streamlining.

According to the MRD, the new Instruction (DCAAI 7642.2)—

… outlines the levels of review required for specific activity codes, and the specific role of each level of review during the course of the audit. It also provides that the individual signing the report will determine what additional reviews are necessary based on the risk of the specific engagement.

As a result, the new process “will result in more timely reviews, less duplication of effort, and audits that are meaningful to the reader and in compliance with auditing standards.” Which is nice, to be sure.

We are sorry, but we cannot provide you with the details of the Instruction. We cannot show you which reviews go with each activity code. We cannot do that because DCAA has chosen not to share its Instruction with the public.

We of course agree that internal agency policies and procedures need not be made public. But the sad truth of the matter is that DCAA could have chosen to make this particular Instruction public in order inform contractors and help to set reasonable expectations regarding the duration between exit conference and publication of the final audit report. DCAA could have chosen to make this particular Instruction public so as to address and somewhat remedy the agency’s historical lack of transparency (and candor) in this area.

That DCAA chose not to do so is a reminder that the audit agency still has not reached the levels of openness and transparency mandated by the Obama Administration. That DCAA chose not to make its Instruction public is a reminder that, no matter how far it has come since 2009, it still has some distance yet to travel.