1. Home
  2. |Insights
  3. |DCAA Issues Guidance on Access to Contractor Internal Audit Reports

DCAA Issues Guidance on Access to Contractor Internal Audit Reports

Client Alert | 1 min read | 08.24.12

In response to a December 2011 GAO report that criticized the DCAA for the number of requests for internal company audit reports it made, DCAA issued new audit guidance on August 14. The new guidance requires auditors at major contractor locations to "establish a process and a central point of contact to obtain and monitor DCAA's access to and use of internal audits," which includes "a method for tracking requests for internal audit reports and working papers, when needed, and the contractor's disposition of these requests" and states that auditors will commence "Access to Records" procedures when access to internal audit reports is denied by the contractor.

Contacts

Insights

Client Alert | 5 min read | 12.12.25

Eleventh Circuit Hears Argument on False Claims Act Qui Tam Constitutionality

On the morning of December 12, 2025, the Eleventh Circuit heard argument in United States ex rel. Zafirov v. Florida Medical Associates, LLC, et al., No. 24-13581 (11th Cir. 2025). This case concerns the constitutionality of the False Claims Act (FCA) qui tam provisions and a groundbreaking September 2024 opinion in which the United States District Court for the Middle District of Florida held that the FCA’s qui tam provisions were unconstitutional under Article II. See United States ex rel. Zafirov v. Fla. Med. Assocs., LLC, 751 F. Supp. 3d 1293 (M.D. Fla. 2024). That decision, penned by District Judge Kathryn Kimball Mizelle, was the first success story for a legal theory that has been gaining steam ever since Justices Thomas, Barrett, and Kavanaugh indicated they would be willing to consider arguments about the constitutionality of the qui tam provisions in U.S. ex rel. Polansky v. Exec. Health Res., 599 U.S. 419 (2023). In her opinion, Judge Mizelle held (1) qui tam relators are officers of the U.S. who must be appointed under the Appointments Clause; and (2) historical practice treating qui tam and similar relators as less than “officers” for constitutional purposes was not enough to save the qui tam provisions from the fundamental Article II infirmity the court identified. That ruling was appealed and, after full briefing, including by the government and a bevy of amici, the litigants stepped up to the plate this morning for oral argument....

View All Insights