Generally Debarments, Suspensions & Referrals (DFARS Subpart 209.4) is imposed as a sanction for conduct indicating that an non-Federal auditor is not fit to practice auditing. Substandard work by a non-Federal auditor may warrant referral for sanctions by the appropriate State licensing authorities or suspension and debarment by the contracting authority. A referral would be appropriate when work has significant inadequacies that make the audit so pervasively deficient that users cannot rely on it.
Criteria on what constitutes a referral condition to state licensing authorities and the procedures to be followed in making a referral are set forth in President’s Council on Integrity and Efficiency (PCIE) Statement No. 4. Procedures to be followed by DoD officials for debarment or suspension are outlined in FAR Subpart 9.4 and in DFARS Subpart 209.4 of Reference (w).
The Federal Acquisition Regulations (FAR) provides guidance on cause for debarments or suspension, procedures to be followed in investigation and referral for debarment and suspension actions, the period of debarment and suspension, reporting requirements relative to debarment and suspension, and identification of debarment and suspending officials.
The Office of the Assistant Inspector General for Audit Policy and Oversight, IG (OAIG APO) is the only official authorized to make referrals for sanctions by appropriate licensing authorities. The DoD audit organizations should take the steps to resolve disagreements on work or product adequacy with the non-Federal auditor prior to proposing a referral. If the circumstances justify a referral, the audit organization shall forward the appropriate documentation and a memorandum with the reason for the proposed referral action to the OAIG APO.
AcqLinks and References:
- DoD Manual 7600.01-M “DoD Audit Manual” – 13 Feb 09
- DoD Instruction 7600.02 “Audit Policies” – 27 April 2007
- DoD Instruction 7650.02 “GAO Reviews and Reports,” – 20 Nov 2006
- Comptroller General of the United States Guidance, “Government Auditing Standard Guidance on GAGAS Requirements for Continuing Professional Education” – April 2005
- DFARS Subpart 237.2 “Advisory and Assistance Services”
- DCAA 7641.90 “Auditing Contractor Information” – Jan 2005
- Example: Purdue University “Internal Office Audit Plan” – 2005
- Template: Internal Audit Plan, U.S. Department of Housing and Urban Development
- Website: DoD Office of Deputy Inspector General of Auditing
- Website: Defense Contract Audit Agency (DCAA)
- Website: DCAA 7640.1 “Contract Audit Manual”
- Website: FAR Part 42 “Contract Administration and Audit Services”