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GAO Reports Deficiencies In DCAA Audit Reports

Client Alert | 1 min read | 09.24.09

After a review that was focused on DCAA offices that issued primarily "clean" opinions and reports, GAO concluded in testimony delivered to the Senate Committee on Homeland Security and Government Affairs on September 23 that there were serious quality problems in 65 of 69 DCAA audit report it reviewed (with minor problems in the other 4) and recommended measures to "strengthen" the role of DCAA in the process. Because of the admittedly biased sample used by GAO, the GAO report does not address or acknowledge quality problems in DCAA findings that are adverse to contractors, although GAO did note that DCAA's decision last year to report contractor systems as either "adequate" or "inadequate," eliminating "inadequate-in-part" findings, could unfairly penalize contractors that do not have material or serious deficiencies and recommended that DCAA seek "outside expertise" to develop audit policy and training on audit standards.

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Client Alert | 3 min read | 04.25.24

JUST RELEASED: EPA’s Bold New Strategic Civil-Criminal Enforcement Collaboration Policy

The Environmental Protection Agency’s (EPA’s) Office of Enforcement and Compliance Assurance (OECA) just issued its new Strategic Civil-Criminal Enforcement Policy, setting the stage for the new manner in which the agency manages its pollution investigations. David M. Uhlmann, the head of OECA, signed the Policy memorandum on April 17, 2024, in order to ensure that EPA’s civil and criminal enforcement offices collaborate efficiently and consistently in cases across the nation. The Policy states, “EPA must exercise enforcement discretion reasonably when deciding whether a particular matter warrants criminal, civil, or administrative enforcement. Criminal enforcement should be reserved for the most egregious violations.” Uhlmann repeated this statement during a luncheon on April 23, 2024, while also emphasizing the new level of energy this collaborative effort has brought to the enforcement programs....