Civilian Contract Audit Services

CIVILIAN 

CONTRACT 

AUDIT SERVICES

Ordering Guide for Contract Audit 

Related Services Under the

GSA Multiple Award Schedule (MAS)

This Ordering Guide sets forth the procedures for issuing 

task orders against the Multiple Award Schedule (MAS), 

Special Item Number (SIN) 541211 Auditing Services. 

U.S. General Services Administration

Professional Services and Human Capital Categories (PSHC)

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Table of Contents

INTRODUCTION ................................................................................................................... 3

SCOPE OF THE ORDERING GUIDE ....................................................................................... 3

WHO IS THIS GUIDE WRITTEN FOR? .................................................................................... 3

THE EMERGING NEED .......................................................................................................... 4

HOW THIS DOCUMENT IS ORGANIZED ............................................................................... 4

SECTION 1. CONTRACT AUDIT SERVICES – UNIQUE CHARACTERISTICS ........................... 5

Areas and Types of Contract Audit Services ...................................................................................... 5

Contract Audit Services throughout the Procurement Lifecycle ........................................................ 5

Qualified Private Auditor ....................................................................................................................... 6

Inherently Governmental Functions ........................................................................................................ 6

Cognizance and Coordination ............................................................................................................... 7

SECTION 2. PROCUREMENT BEST PRACTICES ..................................................................... 8

Align Mission Requirements .................................................................................................................. 8

Determine Accurate Estimates ............................................................................................................. 8

Select Pricing Architecture .................................................................................................................... 8

Develop Requirements .......................................................................................................................... 9

Selection Methodology/Criteria ...................................................................................................... 11

IN DETERMINING THE PROCUREMENT METHOD, IT IS HIGHLY RECOMMENDED THAT ORDERING

AGENCIES CONSIDER AND UTILIZE THE BEST VALUE PROCUREMENT METHOD AS STATED IN FAR PART

8.404(D) AND 8.405-4. ..................................................................................................... 12

SECTION 3: MEASUREMENT OF A SUCCESSFUL AUDIT .................................................... 12

SECTION 4: AN INDUSTRY PERSPECTIVE .......................................................................... 13

DEVELOPING REQUIREMENTS ......................................................................................................... 14

EVALUATING SOLICITATIONS ......................................................................................................... 15

APPENDIX A: VERIFICATION OF LICENSURE .................................................................... 15

APPENDIX B SAMPLES QUALITATIVE EVALUATION FACTORS ....................................... 17

DEPARTMENT OF HOMELAND SECURITY – RFQ HSHQDC-16Q-00081............................ 18

Factor 1: Technical Experience/Understanding and Capabilities ............................................... 18

Factor 2: Management Approach ...................................................................................................... 18

Factor 3: Past Performance ................................................................................................................. 18

PENSION BENEFIT GUARANTEE CORPORATION – RFQ PBGC01-RQ-16-0068................ 19

Factor 1: Technical Approach.............................................................................................................. 19

Factor 2: Past Performance ................................................................................................................. 19

Factor 3: Business Management Approach....................................................................................... 19

Factor 4: Key Personnel and Staffing Plan ......................................................................................19

U.S. AGENCY FOR INTERNATIONAL DEVELOPMENT (USAID) - SPECIAL INSPECTOR GENERAL FOR

AFGHANISTAN RECONSTRUCTION - RFQ 16-233-SOL-00641......................................... 20

Factor 1: U.S. Government Audit Capability ................................................................................... 20

Factor 2: Experience with USAID or USAID and Department of State Contracts ..................... 20

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Factor 3: Afghan-specific Capability ................................................................................................ 20

Factor 4: Past Performance ................................................................................................................. 20

U.S. AGENCY FOR INTERNATIONAL DEVELOPMENT (USAID) - RFQ SOL-267-16-00000820

Factor 1: Past Performance ................................................................................................................. 20

Factor 2: Technical ................................................................................................................................. 20

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION SHARED SERVICES CENTER SOLICITATION

NNX16ZXD040R ............................................................................................................... 21

Factor 1: Technical – Product Work Samples with Corresponding Audit Program .................. 21

Factor 2: Past Performance ................................................................................................................. 21

APPENDIX C.1. SAMPLE CONTRACTOR EMPLOYEE NON-DISCLOSURE AGREEMENT (NDA) 22

APPENDIX C.2. ATTACHMENT TO EMPLOYEE NON-DISCLOSURE AGREEMENT – PRIVACY ACT 25

APPENDIX D. SAMPLE COST ACCOUNTING STANDARDS BOARD DISCLOSURE STATEMENT 27

APPENDIX E. CONTRACT AUDIT WORKING GROUP AGENCIES AND OFFICES ............... 28

OTHER RESOURCES ........................................................................................................... 29

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Information to assist customer 

agencies in using this Guide is 

available online at 

www.gsa.gov/Schedules

This Guide includes examples of 

solicitation excerpts, lists of 

industry partners and many 

other useful documents.

Civilian Contract Audit Services

O R D E R I N G G U I D E F O R C O N T R A C T A U D I T R E L A T E D S E R V I C E S U N D E R 

T H E P R O F E S S I O N A L S E R V I C E S S C H E D U L E

INTRODUCTION

Thank you for choosing the Multiple Award Schedule (MAS) offering of Auditing Services (SIN 541211) to 

fulfill your contract audit services requirement. This Ordering Guide, also referred to as The Guide hereafter, 

will help the ordering office effectively use SIN 541211 to deliver contract audit solutions for mission need. 

MAS is an indefinite delivery/indefinite quantity (IDIQ) vehicle, providing direct access to a variety of

professional services. Using the streamlined procurement procedures in the Federal Acquisition Regulations 

(FAR) Subpart 8.4 Federal Supply Schedules, MAS offers federal agencies access to experienced 

contractors who provide a range of commercial professional services at discounted and competitive prices. 

SIN 541211 is defined by the General Services Administration as “Financial-related audits, performance 

audits, recovery audits, transportation audits, and contract audits in accordance with Generally Accepted 

Government Auditing Standards (GAGAS) and non-GAGAS. 

Perform an independent assessment of an audited entity's financial 

statements in conformity with generally accepted accounting principles, 

financial information, adherence to financial compliance requirements and 

internal controls, or organization or program performance to identify 

areas for improvement.”

Qualified contractors participating under SIN 541211 have been 

pre-screened to ensure they are a licensed Certified Public Accounting 

(CPA) firm. Appendix A provides a list of states, territories and/or 

foreign countries and associated websites to check the most up-to-date licensure status. 

It is important to note that Federal contract audits must: 1) perform in accordance with GAGAS and 2) be 

peer reviewed. Not all companies under this SIN perform engagements requiring compliance with GAGAS, or 

have been peer reviewed. Therefore, both compliance with GAGAS and peer review should be considered 

and included as a requirement when developing the Request for Quotation (RFQ) and evaluation criteria. 

SCOPE OF THE ORDERING GUIDE

The Guide is intended to provide guidance on contract audits and procuring contract audit related services 

through qualified contract auditing firms and their staff. For these services, using SIN 541211 is highly 

recommended. Contract Audits and related services fall under the North American Industry Classification 

System (NAICS) 541211 and Product Service Code (PSC) R704. 

WHO IS THIS GUIDE WRITTEN FOR?

This Guide is a result of a cross-agency collaboration seeking to maximize efficiencies within the civilian 

contract audit procurement process. 

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The Guide is an information resource and starting point for acquisition professionals seeking contract audit 

support through the GSA MAS program. The Guide highlights best practices and suggests recommendations 

to consider when securing a contractor savvy in the discipline and delivery of contract audit services. 

Procuring and conducting Federal contract audits are different from standard financial audits. This Guide 

addresses concepts unique to acquiring Federal contract audits and contract audit related services. It 

presumes the ordering Contracting Officer is proficient in his or her duties. It will not address general 

contracting issues or concepts unless necessary for complete understanding. 

THE EMERGING NEED

While the Defense Contract Audit Agency (DCAA) primarily serves the Department of Defense as the executor 

of contract audits for cost reimbursable contracts, it also serves the civilian agency community. There are, 

however, instances when the DCAA may be unable to fulfill the needs of civilian agencies so certified public 

accounting firms provide a good alternative. 

This Guide is intended to help civilian agencies that cannot use or chose not to use DCAA as their contract 

audit provider. 

HOW THIS DOCUMENT IS ORGANIZED

This document is broken into three sections: 

Section 1. Unique Characteristics of Contract Audits. This section provides an overview of the qualification 

requirements Certified Public Accountants (CPA) to perform contract audits for the Federal government and 

looks at the types of contract audits normally conducted. It highlights the intersection of inherently 

governmental and non- inherently governmental functions as well as addresses the critical subject of 

cognizance and coordination. 

Section 2. Best Practices in Contract Audit Acquisitions. This section outlines key considerations in developing 

your acquisition plan and preparing the task order solicitation. 

Section 3. Measurement of a Successful Contract Audit. The measurement of a successful contract audit boils 

down to performing an impartial evaluation of compliance with applicable regulation and statutory 

requirements. This section discusses the critical elements that will increase the likelihood of quality audit 

deliverables and findings.

Additionally, several Appendices provide additional information and examples: 

• Appendix A. Verification of Certified Public Accountants (CPA) Licensure – This appendix includes a list

of websites that allow Contracting Officers to verify contract licensure.

• Appendix B. Qualitative Evaluation Factors – This appendix provides examples of contract audit

solicitations created by DHS, PBGC, USAID, and NASA. These solicitations provide strong examples of

using qualitative criteria to secure qualified contract audit services providers. Because contract audits are

heavily driven by regulation it is imperative providers are able to offer specifics about their success and

proven processes and procedures.

• Appendices C.1 and C.2 – These appendices include a sample Contractor Employee Non-Disclosure

Agreement and sample Privacy Act Compliance Statement–These samples are useful in creating these

Agreements and creating a complete RFQ package.

• Appendix D. Sample Cost Accounting Standards Board (CAS) Disclosure Statement

• Appendix E. Cross-Agency Membership and Respective Agency Offices

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SECTION 1. CONTRACT AUDIT SERVICES – UNIQUE CHARACTERISTICS

While there are many considerations that set the conduct and delivery of contract audit services apart from 

financial audits, the following factors are valuable in planning targeted procurements. 

Areas and Types of Contract Audit Services

The provision of contract audit services differs from the standard 

financial audit in some key ways. Major areas of emphasis include: 

1. Business Systems

2. Management Policies and Procedures

3. Cost Estimating and Forecasting

4. Internal Controls

5. Compliance with FAR Cost Principles (FAR Part 31)

6. Cost Accounting Standards

7. Pricing Policy (FAR Part 15.4)

Contract audits are independent, professional compliance 

assertions (i.e., proposals, claims, or submissions) made by 

contractors. The sidebar outlines the types of contract audit 

services in the areas of pre- and post-award services, business 

systems audits, and negotiations assistance. 

The term ‘contract audit’ or ‘audit’ is used throughout this guide as 

a generic term to cover all types of engagements to include 

financial audits, examinations, reviews, agreed-upon procedures, 

and performance audits, however ordering agencies should 

exercise caution and diligence in selecting terminology for their 

requirement. 

For a fuller description of the different audits, consult the 

DCAA’s Directory of Audit Programs.

Contract Audit Services throughout the Procurement Lifecycle

It is also helpful to understand the variety of contract audit services which relate to each phase of the contract 

lifecycle. Below is a graphical depiction of the services throughout. 

PRE-AWARD CONTRACT AUDIT SERVICES

• Pre-Award Contract Audit Services

• Contract Price/Cost Proposal Reviews

• Forward Pricing Rate Proposal

Reviews

POST-AWARD CONTRACT AUDIT SERVICES

• Provisional Billing Rate

Recommendations

• Incurred Costs/Final Overhead Rate

Reviews

• CAS Compliance & Adequacy

Reviews

• Penalty Assessment

BUSINESS SYSTEM AUDITS

• Accounting

• Estimating

NEGOTIATION ASSISTANCE

• Fact-finding and analysis of

contractor information after audit

report is issued

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Qualified Private Auditor

A qualified commercial auditor must be— 

− GAGAS Compliant. The auditor performs audits in accordance with GAGAS of the Comptroller

General of the United States.

− Peer Reviewed. The purpose of a peer review is to ensure a CPA firm does quality work in

accordance with industry standards and regulations. The CPA firm must provide a copy of its most

recently completed peer review report, as well as any internal documents issued to address corrective

action for noted deficiencies.

Qualified contractors participating under MAS SIN 541211 have been screened to ensure they are licensed 

CPA firms. (Appendix A provides a resource to confirm current licensure. It provides websites of states, 

territories, and/or foreign countries an ordering agency can check up-to-date licensure statuses.) As the scope 

of SIN 541211 covers financial-related audits, performance audits, and contract audits, not all companies 

under this SIN will perform contract audits as some may focus on audits of financial statements exclusively. 

Inherently Governmental Functions

The subject of inherently governmental functions must be understood and carefully managed during the 

procurement and execution of the contract audit services. The following provides guidance regarding this 

important subject. 

FAR 15.404-1 provides that Contracting Officers have the sole responsibility to determine fair and 

reasonable prices, however FAR 15.404-1(a)(5) provides that ’the contracting officer may request the advice 

and assistance of other experts to ensure that an appropriate analysis is performed.’ 

FAR 7.503 (c )(12) (vii) bars contractors from “Determining whether contract costs are reasonable, allocable, 

and allowable; and ... 

FAR 42.101(a) provides guidance regarding contract auditor responsibilities. Briefly, contract auditors 

provide Contracting Officers with pricing information or audit services in support of the government’s 

independent decisions and determinations. In 42.101(a) the contract auditor’s responsibilities are outlined as: 

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(1) Submitting information and advice to the requesting activity,

based on the auditor's analysis of the contractor's financial and

accounting records or other related data as to the acceptability

of the contractor's incurred and estimated costs;

(2) Reviewing the financial and accounting aspects of the

contractor's cost control systems; and

(3) Performing other analyses and reviews that require access to

the contractor's financial and accounting records supporting

proposed and incurred costs.

After the audit report is received, the Contracting Officer must 

perform an analysis of the report to determine the Government’s 

position. This is frequently done in a pre-negotiation objectives memorandum. The Contracting Officer must 

perform the independent analysis to ensure inherently Governmental responsibilities are not being delegated 

to the auditor. 

Cognizance and Coordination

There are several locations in the FAR that reference cognizance, Cognizant Federal Agency and the 

responsibilities of the Cognizant Federal Agency. The need to coordinate through inter-agency agreements is 

addressed in FAR 42.002.

Determining Who is Cognizant. FAR 42.003(a) states “the Cognizant Federal agency normally will be the 

agency with the largest dollar amount of negotiated contracts, including options. For educational institutions 

(defined as institutions of higher education in the OMB Uniform Guidance at 2 CFR part 200, subpart A, and 20 

U.S.C. 1001) and nonprofit organizations (as defined in the OMB Uniform Guidance at 2 CFR part 200), the 

Cognizant Federal agency for indirect costs is established according to the OMB Uniform Guidance at 2 CFR part 

200, appendices III and IV, respectively”. 

Contract Audit Services. Further, FAR 42.101(b) specifies “Normally, for contractors other than educational 

institutions and nonprofit organizations, the Defense Contract Audit Agency (DCAA) is the responsible 

Government audit agency. However, there may be instances where an agency other than DCAA desires 

cognizance of a particular contractor. In those instances, the two Agencies shall agree on the most efficient and 

economical approach to meet contract audit requirements. For educational institutions (defined as institutions of 

higher education in the OMB Uniform Guidance at 2 CFR part 200, subpart A, and 20 U.S.C. 1001) and 

nonprofit organizations (as defined in the OMB Uniform Guidance at 2 CFR part 200), audit cognizance will be 

determined according to the provisions of the OMB Uniform Guidance at 2 CFR part 200, subpart F.” 

Cost Accounting Standards and Cognizant Federal Agency Responsibilities. The requirements of 48 CFR

Section 9903.201-7 shall, “to the maximum extent practicable, be administered by the Cognizant Federal 

Agency responsible for a particular contractor organization or location, usually the Federal agency responsible 

for negotiating indirect cost rates on behalf of the Government. The Cognizant Federal agency should take the 

lead role in administering the requirements of Part 9903 and coordinating CAS administrative actions with all 

affected Federal agencies. When multiple CAS-covered contracts or more than one Federal agency are involved, 

Agencies should discourage Contracting Officers from individually administering CAS on a contract-by-contract 

basis. Coordinated administrative actions will provide greater assurances that individual contractors follow their 

cost accounting practices consistently under all their CAS-covered contracts and those changes in cost accounting 

practices or CAS noncompliance issues are resolved, equitably, in a uniform overall manner.” 

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Establishing Indirect Rates. Indirect rates are established in accordance with FAR 42.7, however it is 

important to note that per FAR 42.703-1(a), “a single agency shall be responsible for the establishment of the 

final indirect cost rates for each business unit. These rates shall be binding on all Agencies and their 

Contracting Officers, unless otherwise specifically prohibited by statute”. It is imperative that the Contracting 

Officer validate whether or not another Agency has cognizance and has already established indirect rates 

with a business unit prior to establishing their own indirect rates. 

Avoiding Duplicative Audits. FAR Part 42.002 This sub-part supports the need for a primary Agency to 

conduct contract audits on behalf of itself and other Agencies that might have similar interests and needs. It 

provides that “Agencies shall avoid duplicate audits, reviews, inspections, and examinations of contractors or 

subcontractors, by more than one agency, through use of interagency agreements”. To do otherwise, generates 

administrative cost and inefficiency in the acquisition system. This approach recognizes the value of focusing 

the contract audit on the adequacy of management and financial systems and controls, along with transaction 

testing across all business activities, rather than conducting contract-by-contract audits. It also lays the 

foundation for the need to coordinate contract audit activities with relevant agencies. 

SECTION 2. PROCUREMENT BEST PRACTICES

Based on feedback from Price-Cost Analysts, Procurement Contracting Officers (PCOs), Administrative 

Contracting Officers (ACOs), and Inspectors General (IG) planning the features of your audit is a necessary 

first step. The time spent in planning the procurement of contract audit services pays dividends throughout the 

lifecycle of the procurement –contract award, administration, and closeout. 

The task order RFQ should provide instructions to the Offerors on how to identify and call attention to the 

intent to use the specialized skill set. Key considerations to address in developing your acquisition plan and 

preparing the task order RFQ include: 

Align Mission Requirements

Align mission objectives with the statutory audit records requirements; determine necessary contract audit and 

financial advisory services needed; conduct market research/perform due diligence to identify which 

agencies, organizations, or companies are best suited to provide the necessary and timely financial advisory 

services; and identify assumptions. 

Determine Accurate Estimates

It is incumbent upon the ordering office to determine accurate estimates based on identified variables and 

constraints specific to the provided requirements and to the agency itself. Estimates should be based on 

historical data and realistic internal agency analysis to the maximum extent possible. Clearly identified and 

stated variables and constraints enable you to set boundaries of any activity and the associated deliverables. 

They help create the backdrop – they tell how much you can afford to do; how long you can afford to take. 

For each activity and deliverable, there should be some tailored estimates. 

Select Pricing Architecture

It is incumbent upon the agency to identify accurate assumptions and constraints about the audit to get best 

estimates. Determining the appropriate contract type requires the exercise of sound judgment. Here are a few 

considerations as you develop your strategy. 

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Agency Responsibility Notes/Comments

Firm-Fixed 

Price

Estimate types of audits 

and generic delivery 

timeframes for each audit 

type

Establishes a clear, specific, 

agreed upon price up front to be 

paid for acceptable services 

received

Time and 

Materials

Establish a ceiling for level 

of effort

See FAR 8.404(h).

Develop Requirements 

Contract audit services themselves cover a broad range of actions. As part 

of your Request for Quote (RFQ) evaluation, GSA recommends that you 

specifically address both corporate and individual experience for the type 

of contract audit service required. 

Ordering agencies should consider reviewing cognizance and coordinating with other agencies, to include 

DCAA (DCAA-SRFLA-NONDOD-Team@dcaa.mil) prior to placing a task order to ensure the agency’s 

intentions are clear and that there is no duplication of effort. They should also review their internal 

requirements and notify their agency IG prior to placing a task order for contract audit services if required. 

By informing the IG of the intent to order auditing services, the ordering office can mitigate potential concerns 

and issues from the IG after award and ensure task orders meet agency policies. Briefly, the ordering office 

should consider the following: 

− Organizational Conflicts of Interest (OCI). Per FAR Subpart 3.11, FAR Part 9.5 and Schedule Clause

C-FSS-370(f), Contractor Tasks/Special Requirements (November 2003) 

− Non-disclosure Agreements 

− Security Clearance requirements 

− Inherently Governmental Functions - Requirements official should provide the Operational Contracting 

Officer (OCO) with a written determination that these are not included in the scope 

− Data Security – how will data be secured and transferred between the Agency and CPA firm 

− GAGAS Compliance 

− CPA Licensure 

− Deliverable format/s 

− Types, numbers, and frequencies of contract audits to be conducted 

− Applicable regulations to the time period of the audit 

It’s important to note that “Yellow Book” audits encompass many types of audits for which not all CPA firms 

have technical expertise. These include audits of not-for-profits and audits of the government itself, as well as 

contract audit services. Specific experience in contract audit within Yellow Book should be considered when 

evaluating requirements rather than a standard Yellow Book audit compliance requirement. 

Additionally, ordering agencies should consider the American Institute of Certified Public Accountants (AICPA) 

standards and Generally Accepted Government Auditing Standards (GAGAS) have defined words to have 

specific meanings and to carry much weight when it comes to the type of report and the level of assurance the 

Government wishes to receive, as well as the Level of Effort (LOE) for the Offeror, therefore words such as 

“examination,” “audit,” and “review” should not be considered interchangeable.

Create Quality Assurance Surveillance Plan

FAR Part 3, Government 

business must also prohibit 

personal conflicts of interest 

and shall be conducted in a 

manner above reproach 

and, except as authorized 

by statute or regulation, 

with complete impartiality 

and with preferential 

treatment for none. The 

general rule is to avoid 

strictly any conflict of 

interest or even the 

appearance of a conflict of 

interest in Governmentcontractor relationships

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Effective and frequent two-way, face-to-face communication between the CO and contractors including audit 

planning, performance, and reporting is imperative. 

− Identify applicable performance metrics 

− Establish deadlines for the completion of requested audits. For example, the optimal timeline would be 

xx days from claim submission of incurred cost proposals. Once audit has begun, establish a 

preliminary deadline for completion but maintain open communication to identify and solve and 

potential delays or issues. 

− Determine if quality control testing is required and how it will be executed. 

The standards of audit quality should be set early. It is only through consistency that auditors know the 

Agency’s requirements.

Develop Efficient Audit Management Practices 

Risk management is the foundation for implementation of an efficient audit or any oversight management 

process. Simply stated, risk management is the identification, assessment, and prioritization of risks, followed 

by the coordinated and economical application of resources to minimize the impact of those risks. 

Performance Standards in the FAR 1.102-2(c)(2) state: “To achieve efficient operations, the System must shift its 

focus from ‘risk avoidance’ to one of ‘risk management’. The cost to the taxpayer of attempting to eliminate all 

risk is prohibitive. The Executive Branch will accept and manage the risk associated with empowering local 

procurement officials to take independent action based on their professional judgment.” 

To begin, establish definable and measurable auditing criteria, materiality, and acceptable time frames by 

audit type: 

- Materiality Thresholds – Consistent with industry standards, audit firms establish their own materiality 

thresholds to obtain the auditor’s independent position on the item being audited. However, the 

Government has ability to ask the auditor to report all instances of non-compliance, regardless of the 

dollar amount involved. 

- Mitigation – Consider the specific measures designed to reduce the extent of exposure to a risk by 

reducing the severity of consequences or reducing the probability of the risk’s occurrence. 

- Work of Others – The GAO’s Government Auditing Standards state that determinations should be 

made whether other auditors have conducted, or are conducting, audits that could be “relevant” to the

current audit objectives. It also includes guidance on procedures that may be performed to use the 

work, thereby avoiding duplication of efforts and expense. 

Firmly Established Due Dates – Efficient audit management is consequential for both the government and the 

auditor to maximize the investment of both Government and contractor resources. The Contracting Officer 

can request a milestone schedule in the RFQ as part of the technical proposal and then incorporate the 

agreed upon schedule into the task order award. Coordinating with the auditee ahead of time will help to 

ensure there are no major conflicting priorities that could impact the timeline of the Government and/or the 

auditor on any proposed audit schedules. 

The establishment of a risk-based, time-phased audit process with a firm schedule, milestones and due dates 

will support the delivery of quality and timely contract audits. In addition to efficient audit management 

practices, performing audit activities on a concurrent basis throughout the year positively impacts the success 

of the audit program. 

Assemble Request for Quote (RFQ) Package. 

The contractors under MAS SIN 541211 have already been confirmed to have their CPA license at time of 

the award of the schedule contract. Ordering agencies may want to request, as part of the evaluation 

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BEST PRACTICE

Cognizance and Coordination

– to ascertain there is no

duplication of audit efforts,

request the subject contractor

being audited to specify other

agencies they work with. In

many instances the contractor

will have easy access to this

information.

criteria, a confirmation statement from the contractor that they are still a licensed CPA firm and ask for a 

copy of the active license(s).

MAS SIN 541211 contractors were also asked before award of the Schedule contract to submit a peer 

review report and any internal documents to explain what corrective action has been taken regarding any 

deficiencies. Ordering agencies may wish to ask for an updated report as part of the evaluation to document 

any changes since time of original award. 

Ordering offices may wish to ask for specific information on both corporate and individual experience for the 

type of contract audit services you are buying. 

Determine cognizance and coordinate to ascertain there is no duplication of audit efforts by other buying 

offices in your organization, DCAA, or with other agencies. Request the subject contractor undergoing the 

audit, to specify any intra-agency work underway or identify other agencies/components they work with. The 

subject contractor should know which agency/entity is cognizant of their firm. 

Agency can provide and/or ask respondents to provide an estimate of the number of hours to complete a 

given audit, by audit type. This practice serves as a point of comparison 

between proposals and provides the agency insight to evaluate level of effort. 

Attachments to Include in RFQ 

− Sample of the audit report format/s the successful qualified auditor

will use 

− Sample contractor employee non-disclosure agreement for awarded

contractor to use (See Attachment C.1) 

− Sample organizational conflict of interest document for contractor to

submit as part of their proposal 

References to Include in RFQ

− DCAA Contract Audit Manual (CAM) DCAA Manual 7640.1 available at www.dcaa.mil; under

Guidance, select CAM

− DCAA standard audit programs available at www.dcaa.mil , Directory of Audit Programs

− Government Auditing Standards (The Yellow Book )

− Federal Acquisition Regulation, including FAR Part 30 Cost Accounting Standards, FAR Part 31

Contract Cost Principles and Procedures, FAR Part 42 Contract Administration and Audit Services

− Agency Supplemental References as applicable

Selection Methodology/Criteria

− Contractor assumptions for performing the audit – are they the right assumptions? (Supports ability to

validate price/risk)

− Contractor’s list of risk assumptions and financial impact summary of those assumptions

 Are those assumptions acceptable/or not?

− Price reasonableness analysis

 Relevant experience providing Federal contract/grant and/or subcontract/sub-grant audits,

including tangible evidence. Sample work products such as description of project planning and audit 

methodology 

− Considering requiring additional quality standards such as ISO9001Past direct performance

(Individual and Corporate performance as well as Prime or Sub-contractor role)

 May consider CPARS reviews /assessments

− experience using GAGAS and GAGAS compliance when using it

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PEER REVIEW RATINGS

There are three ratings:

1. “Pass”

2. “Pass with Deficiencies”, and

3. “Fail.”

There may be limited 

circumstances where a more 

permissive standard would be 

beneficial (e.g. small or 

underserved markets).

− CPA Licensure 

− Peer Review Rating Acceptability (see box). 

− Pre-Qualified Items 

Organizational Conflicts of Interest (OCI) - A qualified private auditor is one that certifies no conflict of 

interest in performing specified contract audit.

Did the Contractor identify and thoroughly evaluate all potential conflicts of interest? Did they 

recuse themselves for work for which they might have a conflict? (i.e., they cannot evaluate a 

Federal contractor with whom they already have an 

agreement or are under contract with as their client)

- In accordance with FAR 2.101(b), if the Contractor (and any 

subcontractors, consultants, or teaming partners) has or is 

currently providing support or anticipates providing support 

to the Government that creates or represents an actual or 

potential OCI, the Contractor shall immediately disclose this 

actual or potential OCI in accordance with FAR Subpart 9.5. 

The Contractor is also required to complete and sign an OCI 

Statement in which the Contractor (and any subcontractors, 

consultants, or teaming partners) agrees to disclose 

information concerning the actual or potential conflict with 

any proposal for any solicitation relating to any work in the 

task order. All actual or potential OCI situations shall be 

identified and addressed in accordance with FAR Subpart 9.5.Non-Disclosure Agreements

IN DETERMINING THE PROCUREMENT METHOD, IT IS HIGHLY RECOMMENDED THAT ORDERING 

AGENCIES CONSIDER AND UTILIZE THE BEST VALUE PROCUREMENT METHOD AS STATED IN FAR PART

8.404(D) AND 8.405-4.

SECTION 3: MEASUREMENT OF A SUCCESSFUL AUDIT

Success measures for audits differ, based on whether the audit is conducted pre-award or post-award. Preaward, success includes reasonably projecting and quantifying risk in a timely manner. Post-award success

involves accurately verifying and/or evaluating cost/price for compliance with contract terms and regulations 

in a timely manner. It is critical that the contracting office establish definable and measurable auditing 

criteria, materiality, and acceptable time frames by audit type. The design and implementation of proper 

performance metrics will increase the likelihood of quality audit deliverables and findings. 

Assessing Audit Quality

Risk Assessment

The auditor will identify the risk(s) associated with the requirements being examined. Once 

identified, the experienced audit team will scope the risks and develop procedures to test 

how the identified risks are affecting the requiring activity.

Planning and 

Coordination

Audits will be properly planned and coordinated with the Requestor/Contracting Officials to 

ensure the end state meets the need of the agency. Auditors should have a thorough 

knowledge of the contractual matters and circumstances affecting audits. Auditors will work 

with the requesting official to ensure requirements are clearly identified.

Audit Contents

A quality audit is one that is well documented. The auditor will clearly document answers to 

the following questions in the working papers:

− What procedures were performed?

− Why were those procedures performed?

− How were those procedures performed and how do they support the conclusions?

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Assessing Audit Quality

− When were those procedures performed?

− How does the gathered evidence support the findings and conclusions?

Transaction Testing

Transaction testing is focused on the areas with the highest risk. Transaction Tests will be 

designed and tailored to gather evidence related to the risk areas identified during risk 

assessment. In addition, Transaction Testing also serves to identify other areas that 

potentially require the scope to be expanded, which will require the Risk Assessment to be 

modified. In some cases tests for allowability, allocability, and reasonableness of the cost 

incurred in accordance with FAR Part 31 terms and conditions of the contract and/or other 

applicable federal regulations will apply.

Evidence/Work Papers

The evidence gathered through these procedures must be sufficient and appropriate to 

support the findings and conclusions. There is no set amount as to how much evidence is 

sufficient – an audit team will apply best judgment based on prior successful experience in 

relation to the assertion being audited.

Experience and 

Technical Knowledge

The staff assigned to perform the audit must collectively possess adequate professional 

competence needed to address the audit objectives and perform the work in accordance with 

GAGAS.

The staff assigned to conduct an audit in accordance with GAGAS should collectively possess 

the technical knowledge, skills, and experience necessary to be competent for the type of 

work being performed before beginning work on that audit.

Consistent Conclusions If the contract audit is performed well, a similarly situated auditor, with the same evidence 

and applied procedures would reach the same conclusions.

Timeliness Audits should be performed and reports provided to the agency before their need expires, 

such as contract period or statute of limitations.

Contract Audit 

Compliance

The contract audit must be in accordance with GAGAS and will be compliant with the 

contract terms and applicable government acquisition regulations.

GAGAS Compliance Contract audits are required to comply with GAGAS. The GAGAS provides guidelines that 

an audit team must follow when performing an audit.

Judgment, based on experience and a deep understanding of the requirement and the adherence to statutory 

regulations plays heavily into the quality of the contract audit. The documentation in the working papers must 

be clear and explicit as to what, how, and why the procedures performed support the findings and 

conclusions. 

There is no universal checklist for ascertaining the quality of an audit; some professional judgment is 

necessary. GAGAS 3.68 states, “Professional judgment does not mean eliminating all possible limitations or 

weaknesses associated with a specific audit, but rather identifying, assessing, mitigating, and explaining them.” 

Thus, the documentation in the working papers must be clear and explicit as to how and why the procedures 

performed support the findings and conclusions. 

In summary, the success of an audit is essentially judged by whether the audit is provided in conformance with 

professional standards and applicable regulations, meets the needs of the ordering office, and is completed 

in a timely manner. 

SECTION 4: AN INDUSTRY PERSPECTIVE

Industry partners who have performed audit services in the government marketplace collaborated with the 

Working Group and provided the following key insights for ordering agencies to consider when developing 

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their requirements, evaluating their solicitations, and administering their awards. 

DEVELOPING REQUIREMENTS 

- Considering requiring additional quality standards such as ISO9001 

Pricing Considerations

The following assumptions should be considered when applying a fixed-price strategy: 

− Agency Support. Auditors require the support of the Agency personnel to achieve timely completion 

of the project. Support includes the collection of relevant documents (paper or electronic) and the 

scheduling of interviews and coordination of meetings. 

− Project Management. The requesting Agency will designate a management-level individual to 

oversee the conduct of this project, including coordination of the resources needed and review of draft 

deliverables. The personnel assigned to the project will review draft deliverables on a timely basis. 

− Consistent with Government Auditing Standards, the Agency’s management is responsible for making 

an informed judgment on performance audits results and agree to:

 Designate a suitably skilled, knowledgeable, and experienced management-level individual to 

be responsible and accountable for overseeing the performance audits 

 Establish, maintain, and monitor the progress of the performance audits to make certain that they 

meet management’s objectives 

 Make all management decisions and perform all management functions related to the 

performance audit and accept full responsibility for such 

 Evaluate the adequacy of the services performed and findings that result 

− Agency management should also agree

 that all records, documentation, and information the auditor requests in connection with 

performance audits will be made available as well as assist with any issues encountered in 

obtaining contractor (auditee) records requested, 

 that all material information will be disclosed 

 that the auditor will have the full cooperation of contractor personnel. In completing the 

performance audits, or other types of audits the requesting Federal agencies may request, 

 The auditor will make specific inquiries of contractor management and request documentary 

evidence regarding the performance audit objectives and, where appropriate, the effectiveness 

of internal control and obtain a representation letter from contractor management about these 

matters. 

Cost Savings Measures 

- In developing Acquisition Strategies and forming contract vehicles, consider flexible options such as a 

Blanket Purchase Agreement to achieve time-saving and financial efficiencies of ordering audits for 

multiple contractors and multiple similar engagements under one task order, as opposed to issuing 

various task orders by individual audit. Ordering agencies may have Contract Line Items (CLIN) by 

contractor or by individual audit under one award. This will lead to a lesser contract administration

burden on the Government and will aid in reducing overall cost because vendors can maximize 

efficiencies by using economies of scale and staffing task orders accordingly. 

- Efficiencies in allowing for multiple-purpose reports; for example, by grouping a contractor’s incurred 

cost audits in two-to-four Fiscal Year (FY) increments or by grouping multiple business systems of the 

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same contractor in one report. This reduces the cost of planning and reporting on multiple years/items 

separately and gives Contracting Officers (CO) more information in the appropriate context and 

form.

- Consider the use and authorization of teaming arrangements. Often teaming arrangements can assist 

in applying the appropriate safeguards when a vendor has an Organizational Conflict of Interest 

(OCI) while still being able to bid on a task order that might contain many other non-conflicted audits. 

However, ordering agencies should note and enforce that teaming partners and subcontractors must 

still meet the requirements of the “Qualified Private Auditor” section.

- Concepts of materiality, using the work of others, and report/engagement efficiency expectations are 

critical elements that make large differences in Level of Effort (LOE)

SOW Development 

- If an agency does not have a standard report format they prefer, it may be beneficial to ask the 

Offeror to submit a report template used by their firm for evaluation.

- Although GAGAS incorporates by reference the American Institute of Certified Public Accountants 

(AICPA) standards, such as the Statements on Auditing Standards (SAS) and the AICPA’s Statements on

Standards for Attestation Engagements (SSAE), it is a good practice to identify the most important 

AICPA standards (GAAS or SSAE) that should be taken into consideration in the RFP. This would 

provide a better understanding to the CPA (Offeror) when preparing the technical portion of the RFQ. 

EVALUATING SOLICITATIONS 

− Depending on the contents of a Non-Disclosure Agreement, Offerors may not be able to provide 

actual work products without significant redactions 

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APPENDICES

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15 | Page 

APPENDIX A: VERIFICATION OF LICENSURE

STATE WEBSITES TO VERIFY CPA LICENSURE

Alaska https://www.commerce.alaska.gov/web/cbpl/ProfessionalLicensing/BoardofPublicAccountancy.aspx

Arizona http://www.azaccountancy.gov/CPADirectory/CPASearch.aspx

Arkansas https://www.ark.org/asbpa_olr/app/search.html

California https://www.dca.ca.gov/cba/consumers/license-lookup.shtml#:~:text=Welcome%20to%20the%

20California%20Board,CPA%20or%20California%20Accounting%20Firm

Colorado https://apps.colorado.gov/dora/licensing/Lookup/LicenseLookup.aspx 

Connecticut https://www.elicense.ct.gov/Lookup/LicenseLookup.aspx 

Delaware https://dpronline.delaware.gov/mylicense%20weblookup/Search.aspx

District of Columbia https://dlcp.dc.gov/node/1617636#:~:text=The%20public%20is%20encouraged%20to,Accountancy%20to%20a%

20central%20database.

Florida https://www.myfloridalicense.com/wl11.asp?mode=0&SID=

Georgia http://sao.georgia.gov/gsba-services

Hawaii https://pvl.ehawaii.gov/pvlsearch/

Idaho https://dopl.idaho.gov/boa/

Illinois https://online-dfpr.micropact.com/lookup/licenselookup.aspx

Indiana https://mylicense.in.gov/everification/Search.aspx

Iowa https://ia-plb.my.site.com/LicenseSearchPage

Kansas http://oitsapps.ks.gov/boa/SearchforFirms.aspx

Kentucky https://secure.kentucky.gov/FormServices/CPA/FirmRenewal/Search

Louisiana https://elicense.cpaboard.la.gov/Lookup/LicenseLookup.aspx

Maine https://www.pfr.maine.gov/almsonline/almsquery/welcome.aspx?board=4110

Maryland https://www.dllr.state.md.us/cgibin/ElectronicLicensing/OP_search/OP_search.cgi?calling_app=CPA::CPA_qselect

Massachusetts https://elicensing21.mass.gov/CitizenAccess/GeneralProperty/PropertyLookUp.aspx?isLicensee=Y

Michigan https://www.lara.michigan.gov/colaLicVerify/

Minnesota https://boa.state.mn.us/findCPA.html

Mississippi https://www.msbpa.webapps.ms.gov/publicView/PublicDefault.aspx

Missouri https://pr.mo.gov/accountancy-licensee-search.asp

Montana https://ebizws.mt.gov/PUBLICPORTAL/searchform?mylist=licenses

Nebraska http://www.nbpa.ne.gov/search/

Nevada http://www.nvaccountancy.com/

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16 | Page 

STATE WEBSITES TO VERIFY CPA LICENSURE

New Hampshire https://forms.nh.gov/licenseverification/

New Jersey https://newjersey.mylicense.com/verification/Search.aspx

New Mexico https://www.rld.nm.gov/about-us/public-information-hub/consumer-protection/verify-a-license/

New York http://www.op.nysed.gov/opsearches.htm 

North Carolina https://nccpaboard.gov/welcome/search-the-database/

North Dakota https://cpaverify.org/

Ohio https://elicense.ohio.gov/oh_verifylicense

Oklahoma https://www.ok.gov/oab_web/Departments/Licensing/index.html

Oregon http://licenseesearch.oregonboa.com/ 

Pennsylvania https://www.pals.pa.gov/ 

Rhode Island https://elicensing.ri.gov/Lookup/LicenseLookup.aspx 

South Carolina https://verify.llronline.com/LicLookup/Acct/Acct.aspx?div=15

South Dakota https://apps.sd.gov/ld01DOL/Template/main.aspx?templateid=22 

Tennessee http://verify.tn.gov/ 

Texas http://www.tsbpa.state.tx.us/general/database-search.html

Utah https://secure.utah.gov/llv/search/index.html 

Vermont 

Virginia https://cpaportal.boa.virginia.gov/Verification/

Washington https://data.wa.gov/Consumer-Protection/CPA-Search-Board-of-Accountancy/pqu3-uhwj

Wisconsin https://app.wi.gov/licensesearch 

West Virginia https://apps.wv.gov/accountancy/licensure/LicenseVerification/Default.aspx 

Wyoming https://cpaboard.wyo.gov/public-info/verify-a-cpa-or-cpa-firm

Revised May 2023

https://secure.professionals.vermont.gov/prweb/PRServletCustom/app/NGLPGuestUser_/

V9csDxL3sXkkjMC_FR2HrA*/!STANDARD?UserIdentifier=LicenseLookupGuestUser

National Association of State Boards of Accountancy (NASBA): https://cpaverify.org/ 

Note: Missing the States of Delaware, Hawaii, Utah, and Wisconsin; Includes Guam, Puerto Rico, and U.S. Virgin Islands 
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APPENDIX B 

SAMPLES

QUALITATIVE EVALUATION 

FACTORS

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Lesson Learned: “The samples were 

beneficial – reading of sample reports 

we were able to identify which firms 

had experience in contract audits 

verses financial audits. However, a 

lesson learned - - we were 

overwhelmed by the responses and 

since each company submitted their

“best” reports – they submitted 

lengthy, complex examples. This was 

time consuming for the evaluation 

team. Suggest less than three samples 

unless you are sure you are not

receiving a lot of quotes.”

Lesson Learned: “We allowed too many pages for the technical volume. Limit the pages – a firm should be able 

to summarize their quality control process and ability to respond to multiple geographically disbursed 

assignments in a few pages. Once again, the volume of responses and multiple pages in the technical quote was 

unnecessarily time consuming for the technical team.”

DEPARTMENT OF HOMELAND SECURITY – RFQ HSHQDC-16Q-00081

Factor 1: Technical Experience/Understanding and Capabilities

The Government will evaluate the degree to which the Quoter possesses experience and capability in performing contract 

audit and review services, including the audit/review services as specified in

the Statement of Work (SOW), Audit Requirements. The evaluation will

consider the type of work performed and relevancy to the SOW requirements, 

the demonstration of corporate and staff experience, the scope of the 

engagement(s), and how recently the engagement was performed.

The Government will evaluate the degree to which the Quoter demonstrates

an understanding of the Audit Reporting Requirements in the Statement of 

Work (Attachment 2), through the content and structure of submitted work

samples. The evaluation will assess the redacted work product samples for 

clarity in findings and recommendations. The evaluation will assess whether the 

audit opinion and findings are well supported by the specific evidence 

obtained during the audit, the applicable law and regulations, and/or the 

auditee’s own policies and procedures.

The Government will be reviewing the work sample to see if the findings and 

recommendations are clearly stated and supported.

Factor 2: Management Approach

The Government will evaluate the Quoter’s approach to managing the customer relationship, establishing quality control checks

for work products, and integrating any teaming/subcontracting efforts with the prime contractor’s effort, including methods to 

ensure personnel affiliation with either the prime or the subcontractor is transparent. The Government will also evaluate the

Quoter’s plan to perform simultaneous contract audit and review services at Government/Contractor locations that are 

geographically disbursed.

The Government will evaluate the Quoter’s plans to recruit, retain, and manage qualified personnel and ensure sufficient levels 

of staffing throughout the contract performance period, including during periods of work load fluctuation.

Factor 3: Past Performance

The Government will evaluate the extent to which the Quoter’s Past Performance demonstrates its capability to deliver high 

quality products and services similar in size, scope, and complexity to the requirements listed in the RFQ either as a prime 

Contractor or Subcontractor. Only work performed within the past three years and of similar complexity and magnitude to the 

work identified in the SOW will be evaluated.

Each Quoter will be evaluated on their Past Performance under existing and prior contracts. The Government will focus its 

evaluation on the information submitted by the Quoter in response to the instructions provided in this RFQ, and the Past 

Performance Information, Contractor Performance Customer Survey Questionnaire, Attachment 3, sent directly to the 

Contracting Officer that demonstrates the quality of the Past Performance relative to the size, scope, complexity, and 

relevancy to the procurement under consideration. Also, related Past Performance information may be sought and utilized by 

DHS for the purpose of evaluating the Quoter’s Past Performance from a variety of sources including the PPIRS/CPARS 

database, other Government contracting activities, evaluator first-hand knowledge, the Excluded Parties List System (EPLS), 

and other Government reports. If the Quoter does not have a record of past performance, then it will not be evaluated 

favorably or unfavorably with respect to past performance and will receive a neutral rating.

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PENSION BENEFIT GUARANTEE CORPORATION – RFQ PBGC01-RQ-16-0068

Factor 1: Technical Approach

The Offeror’s technical approach shall be evaluated to the extent to which they demonstrate the ability to accomplish the 

requirements described in all sections of the Performance Work Statement (PWS). Offerors will be evaluated on their technical 

analysis of work areas in the PWS and on the extent to which capability to perform the work is demonstrated, being both 

onsite and offsite, and with respect to the backlog and to ongoing requirements, as required in the PWS.

Factor 2: Past Performance

The Offeror shall provide at least three (3) past performance references. If an Offeror submits more than three references, the 

agency will evaluate three references of its own choosing. Each effort shall be recent (performed within 3 years) and relevant 

to PBGC’s present requirement (e.g., finding temporary attorney services for other Federal agencies to perform tasks similar 

to those listed in the performance work statement).

Past performance references must include: the name of the agency for which the services were provided, a point of contact for

the effort at the agency (including telephone number or e-mail address), the date the services were performed, and a 

description of the services provided. Offerors should ensure that points of contact are still employed by the agencies and that 

contact information is current. Reference responses will be evaluated based upon the timeliness (e.g., degree to which the 

Offeror promptly responded to and fulfilled client service requests), quality (e.g., degree to which temporary personnel 

satisfactorily performed their assignments), and responsiveness (e.g., degree to which Offeror accommodated client 

requirements).

An Offeror without a record of relevant past performance or for whom information on past performance is not available will 

not be evaluated favorable or unfavorable on past performance. Offerors without a record of relevant past performance will 

be given a neutral rating.

Factor 3: Business Management Approach

The Government shall evaluate the proposed Offeror’s ability to the extent to which they can demonstrate successful 

performance under the PWS and its attention to initial and continually improved quality assurance.

Factor 4: Key Personnel and Staffing Plan

The Offeror shall be evaluated on the extent, depth and quality of the Key Personnel’s relevant work experience, as well as 

the quality and applicability of their education, and technical experience in accordance with the requirements of Section 4, 

Special Contract Requirements.

Offeror shall be evaluated to the extent to which they demonstrate ability to provide non-key personnel as required.

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U.S. AGENCY FOR INTERNATIONAL DEVELOPMENT (USAID) - SPECIAL 

INSPECTOR GENERAL FOR AFGHANISTAN RECONSTRUCTION - RFQ 16-233- 

SOL-00641

Factor 1: U.S. Government Audit Capability

In this evaluation factor the Government will evaluate the degree to which the offeror demonstrates capability of performing 

a financial audit of a government contractor in compliance with U.S. Government policies, procedures, laws, and regulations.

Factor 2: Experience with USAID or USAID and Department of State Contracts

In this evaluation factor the Government will evaluate the degree to which the offeror demonstrates:

− An understanding of the U.S. Agency for International Development or Department of State’s contractlifecycle 

process, preference given for experience with U.S. Agency for International Development or U.S. Agency for 

International Development and Department of State Contingency Contracting

− Prior experience auditing U.S. Agency for International Development or Department of State contracts,preference 

given for experience performing incurred –cost audits

Factor 3: Afghan-specific Capability

In this evaluation factor the Government will evaluate the degree to which the offeror demonstrates:

− Prior international audit experience and ability to travel internationally

− A physical presence in or access to an international affiliate able to work in Afghanistan

− Experience working in conflict environments (e.g. Afghanistan, Iraq, Sudan, etc.)

− Prior experience with Federal agencies implementing development programs in Afghanistan

− Experience evaluating costs incurred in Afghanistan

− Competence with written communications in English and staff with a knowledge of Dari and Pashto languages with the 

ability to read, speak and translate those languages and English

Factor 4: Past Performance

The government will review the projects that the offeror is currently performing, or performed (at least in part) during the 

thirty-six months preceding the date that quotes are due. If subcontractors are included in the quote, their single project 

reference (one for each subcontractor proposed) will also be included in the overall past performance evaluation.

***************************************************************************************************

U.S. AGENCY FOR INTERNATIONAL DEVELOPMENT (USAID) - RFQ SOL-267- 

16-000008

Factor 1: Past Performance

Past performance will be evaluated based on the implementation of projects or engagements similar in scope, size and 

complexity as evidenced by performance records and the testimony of clients. Vendors without evidence or record of relevant 

past performance will be evaluated neutrally for this criterion.

Factor 2: Technical

− Ability to provide sufficient and qualified personnel to meet the needs of the statement of work and achieve the 

dates in the audit milestone plan.

− Provide a realistic, achievable audit milestone plan that completes all audits within 18 months.

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NATIONAL AERONAUTICS AND SPACE ADMINISTRATION SHAREDSERVICES 

CENTER SOLICITATION NNX16ZXD040R

Factor 1: Technical – Product Work Samples with Corresponding Audit Program

The Government will evaluate the Offeror’s product work samples to ensure each sample addresses all four elements 

identified below:

1. The objectives, scope, and methodology of the audit;

2. The audit results, including findings, conclusions, and recommendations, as appropriate;

3. A statement about the auditors’ compliance with GAGAS;

4. A summary of the views of responsible contractor official(s)

Factor 2: Past Performance

The Government will not award to an Offeror that receives a rating of Very Low Level of Confidence in this factor. Past 

Performance will be evaluated based on the results of work performed that is determined to be relevant to this requirement.

− Offerors will also be evaluated on the quality of same/similar work performed as a prime contractor or a 

subcontractor/teaming partner within the last FIVE (5) years, using the supporting documentation providedby the 

Offeror.

− Offerors are cautioned to take extreme care in identifying past and current contracts for reference that are both 

relevant and accurately reflect the Offeror’s past experience.

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APPENDIX C.1. SAMPLE CONTRACTOR EMPLOYEENON-DISCLOSURE 

AGREEMENT (NDA)

CONTRACTOR EMPLOYEE NON-DISCLOSURE AGREEMENT

Contract Audit Sow – Attachment #

Contract #

AGENCY NAME

REFERENCES: 48 CFR (Federal Acquisition Regulation (FAR)) Section 3.104, 5.401, 24.102 and relevant corresponding 

sections of the Agency Acquisition Regulation (AAR).

NON-DISCLOSURE OF PROPRIETARY/CONFIDENTIAL DATA

While employed by the (Insert Contractor’s name), hereinafter referred to as “Contractor,” in support of Contract (Insert Contract

number), hereinafter referred to as “Contract,” you may have, or have access to, information or data of a personal nature about an 

individual, or proprietary information or data submitted by or pertaining to an institution or organization. Such information may be

nonpublic, sensitive, confidential, privileged, and proprietary or contain Personally Identifiable Information (PII) and is hereinafter 

referred to as “confidential information/records.”

This Non-Disclosure Agreement (NDA) - 

- Addresses terms used herein; 

- Explains how confidential information/records shall be handled;

- Describes the potential penalties for inappropriately disclosing confidential information/records obtained under the Contract;

- Requires you to affirm - 

▪ You agree to take all necessary steps to prevent disclosure, dissemination, publication or distribution ofconfidential 

information/records to any party outside the Government, unless otherwise authorized; and,

▪ That all confidential information/records obtained or generated under Contract shall:

* Not be disclosed, except as authorized by law or under the terms of the Contract;

* Be used exclusively in the performance of this Contract; and,

* Not be used to engage in any other actions, venture or employment where the confidential 

information/records will be used for the profit of any party.

Please also see the Attachment to this NDA, entitled Chapter 5 of the Code of Federal Regulation (CFR) § 2635.703(b), “Standards of 

Ethical Conduct for Employees of the Executive Branch.” For the purposes of this NDA and work on this Contract, FAR Part 24, 

Protection of Privacy and Freedom of Information, the Privacy Act requirements identified in the Attachment apply to Contractor 

employees working on the Contract.

Your employer is required to restrict access to confidential information/records to the minimum number of employees necessary for 

performance of the Contract and instruct employees who will have access to the same, as to the - 

- Proprietary nature of the information; 

- Relationship under which they have possession; and

- How to administer such information.

DEFINITIONS 

CONFIDENTIAL INFORMATION: As used in the Agency Acquisition Regulation (AAR) ###.##.#, Confidential Information, “...means 

information or data of a personal nature about an individual, or proprietary information or data submitted by or pertaining to an 

institution or organization.”

NONPUBLIC INFORMATION is information that an employee gains by reason of Contract employment and that he/she knows or 

reasonably should know is not available to the general public. It includes information that - 

− Is protected under the Privacy Act of 1974 and is routinely exempt from disclosure under the Freedom of Information Act or 

otherwise protected from disclosure by statute, Executive order, law, or regulation;

− Is designated as “confidential” by (AGENCY NAME); or 

− Has not actually been disseminated to the general public and is not authorized to be made available to the public on 

request. (See Standards of Ethical Conduct for Employees of the Executive Branch, 5 C.F.R. § 2635.703(b).)

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CONTRACTOR EMPLOYEE NON-DISCLOSURE AGREEMENT - AGENCY NAME (continued)

PRIVILEGED OR PROPRIETARY INFORMATION: Information related to trade secrets, processes, operations, style of work, or 

apparatus, or the identity of confidential statistical data, amount or source of any income, profits, losses, or expenditures of any person, 

firm, partnership, corporation, or association. This type of information could include, but is not limited to, certain types of information 

submitted as part of the acquisition process or Contractor proprietary information. Federal law prohibits the unauthorized disclosure of 

trade secrets, or commercial or financial information. (See Procurement Integrity Act, 41 U.S.C. § 423, also protects this type of information 

and carries criminal and civil penalties, such as fines, imprisonment of 5 years or less, or adverse personnel actions; and Trade Secrets Act, 18

U.S.C. § 1905.) 

USE OF CONFIDENTIAL INFORMATION/RECORDS, NONPUBLIC OR PRIVILEGED/PROPRIETARY INFORMATION

All information gained under this Contract shall be held confidential until such time as the information is made available to the public, as 

authorized. This is not intended to restrict the rights of third parties such as law enforcement agencies, courts/administrative tribunals of 

proper jurisdiction, or congressional committees, from securing the release of protected information pursuant to their legal authority. No 

confidential information shall be provided to the public unless it is already available to the public, such as through a public web page or 

another publication, except through the (AGENCY NAME) Freedom of Information Office. 

For any Confidential, Nonpublic or Privileged/Proprietary Information/records that may be furnished to you or that you gain access to in 

the course of your official duties under this Contract, you should:

− Use this information only for the purpose of performing official Contract duties;

− Refrain from disclosing or discussing the information with any person who does not need the information for purposes of 

performing official Contract duties;

− Refrain from copying, for other than official purposes, all or part of this information that may be provided to you in the course 

of your official (AGENCY NAME) duties, and when finished reviewing or utilizing such information for official Contract duties, 

store or dispose of such materials as specifically directed; and

− Advise your Supervisor immediately if any non-disclosable information that is/was maintained by, or in the possession of, the 

Contractor is disclosed, whether intentionally or unintentionally, or if this information is used or handled in a manner inconsistent 

with this NDA.

USE OF CONFIDENTIAL INFORMATION FOR FINANCIAL GAIN IS PROHIBITED: 

Under applicable ethical standards (See Standards of Ethical Conduct for Employees of the Executive Branch, 5 C.F.R. § 2635.703), you 

shall not engage in a financial transaction using confidential information/records or nonpublic information, nor allow the improper use of 

such information to further your own private interest or the interests of another person, whether through advice or recommendation, or by 

knowingly disclosing such information.

REQUESTS FOR CONFIDENTIAL INFORMATION/RECORDS

Before disclosing any information that may constitute nonpublic information, or if you have any questions about whatconstitutes nonpublic 

information, please also consult with your Supervisor. Any response to a request for confidential information/records that is related to 

this Contract shall also be referred to your Supervisor. In the event that Supervisors have legal questions regarding these issues, they 

should promptly contact the Contractor Program Manager/Director, who will contact the Contracting Officer or Contracting Officer’s 

Representative (COR).

POST EMPLOYMENT RESTRICTIONS

All confidentiality obligations identified herein apply even after the employee no longer possesses the confidential information/records 

and/or has left the Contractor’s employ. The unauthorized disclosure of such information may result in fines and/or imprisonment for up 

to one (1) year and removal from office or employment.

Page 2

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24 | Page 

CONTRACTOR EMPLOYEE NON-DISCLOSURE AGREEMENT - AGENCY NAME

AFFIRMATION

I, the undersigned, as a condition of being granted access to work on the Contract, do hereby affirm - 

− The information provided by the Government, obtained from the Contractor(s) or generated under this Contract, may be 

considered confidential, nonpublic, and/or privileged, or proprietary; 

− The information obtained or generated under contract shall be used exclusively in the performance of this Contract and all 

necessary steps will be taken to prevent disclosure, dissemination, publication or distribution of such information to anyparty 

outside the Government, unless otherwise authorized;

− Proprietary information will not be used to engage in any other actions, venture or employment where it will be used for the 

profit of any party;

− My Supervisor will be contacted if I have any questions concerning this matter; 

− I have read the Attachment to this Non-Disclosure Agreement entitled “Privacy Act, 5 CFR § 2635.703(b), Employee 

Standards of Conduct; and,

− The making of a false, fictitious, or fraudulent affirmation may render the maker subject to prosecution under title 18, United 

States code, Section 1001.

These provisions are consistent with and do not supersede, conflict with, or otherwise alter the employee obligations, rights, or liabilities 

under law or regulation.

 / 

Signature of Employee/ Date Type individual’s name and title

 / 

Signature of Witness/ Date Type witness name and title

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APPENDIX C.2. ATTACHMENT TO EMPLOYEE NON-DISCLOSURE AGREEMENT

– PRIVACY ACT

PRIVACY ACT

References: 5 CFR § 2635.703(b)

EMPLOYEE STANDARDS OF CONDUCT

(a) General. All employees are required to be aware of their responsibilities under the Privacy Act (the Act) of 1974, 5U.S.C. 

552a. Regulations implementing the Act are set forth in 45 CFR 5b. Instruction on the requirements of the Act and regulation shall be 

provided to all new employees of the Department. In addition, supervisors shall be responsible for assuring that employees who are 

working with systems of records or who undertake new duties which require the use of systems of records are informed of their 

responsibilities. Supervisors shall also be responsible for assuring that all employees who work with such systems of records are 

periodically reminded of the requirements of the Act and are advised of any new provisions or interpretations of the Act.

(b) Penalties. 

1. All employees must guard against improper disclosure of records which are governed by the Act. Because of the serious 

consequences of improper invasions of personal privacy, employees may be subject to disciplinary action and criminal 

prosecution for knowing and willful violations of the Act and regulation. In addition, employees may also be subject to 

disciplinary action for unknowing or unwillful violations, where the employee had notice of the provisions of the Act and 

regulations and failed to inform himself sufficiently or to conduct himself in accordance with the requirements to avoid 

violations.

2. The Department may be subjected to civil liability for the following actions undertaken by its employees: 

(a) Making a determination under the Act and §§5b.7 and 5b.8 of the regulation not to amend an individual's record 

in accordance with his request, or failing to make such review in conformity with those provisions 

(b) Refusing to comply with an individual's request for notification of or access to a record pertaining to him; 

(c) Failing to maintain any record pertaining to any individual with such accuracy, relevance, timeliness, and 

completeness as is necessary to assure fairness in any determination relating to the qualifications, character, rights, 

or opportunities of, or benefits to the individual that may be made on the basis of such a record, and consequently 

a determination is made which is adverse to the individual; or

(d) Failing to comply with any other provision of the Act or any rule promulgated thereunder, in such a way as tohave 

an adverse effect on an individual.

3. An employee may be personally subject to criminal liability as set forth below and in 5 U.S.C. 552a (i):

(a) Any officer or employee of an agency, who by virtue of his employment or official position, has possession of, or 

access to, agency records which contain individually identifiable information the disclosure of which is prohibited by 

the Act or by rules or regulations established thereunder, and who, knowing that disclosure of the specific material 

is so prohibited, willfully discloses the material in any manner to any person or agency not entitled to receive it,

(b) Any officer or employee of any agency who willfully maintains a system of records without meeting thenotice 

requirements [of the Act] shall be guilty of a misdemeanor and fined not more than $5,000.

Rules Governing Employees Not Working With Systems of Records. 

Employees whose duties do not involve working with systems of records will not generally disclose to any one, without specific 

authorization from their supervisors, records pertaining to employees or other individuals which by reason of their official duties are 

available to them. Notwithstanding the above, the following records concerning Federal employees are a matter of public record and 

no further authorization is necessary for disclosure:

1) Name and title of individual.

2) Grade classification or equivalent and annual rate of salary. 

3) Position description. 

4) Location of duty station, including room number and telephone number. In addition, employees shall disclose records which 

are listed in the Department's Freedom of Information Regulation as being available to the public.

5) Requests for other records will be referred to the responsible Department official. This does not preclude employees from 

discussing matters which are known to them personally, and without resort to a record, to official investigators of Federal 

agencies for official purposes such as suitability checks, Equal Employment Opportunity investigations, adverse action 

proceedings, grievance proceedings, etc.

Rules Governing Employees Whose Duties Require Use Or Reference To Systems Of Records

Employees whose official duties require that they refer to, maintain, service, or otherwise deal with systems of records (hereinafter 

referred to as “Systems Employees”) are governed by the general provisions. In addition, extra precautions are required and systems 

employees are held to higher standards of conduct.

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PRIVACY ACT (Continued)

(1) Systems Employees shall: 

(a) Be informed with respect to their responsibilities under the Act;

(b) Be alert to possible misuses of the system and report to their supervisors any potential or actual use of the system which they 

believe is not in compliance with the Act and regulation;

(c) Make a disclosure of records within the Department only to an employee who has a legitimate need to know the record in the 

course of his official duties; 

(d) Maintain records as accurately as practicable.

(e) Consult with a supervisor prior to taking any action where they are in doubt whether such action is in conformance with the Act 

and regulation.

(2) Systems Employees shall not: 

(a) Disclose in any form records from a system of records except 1) with the consent or at the request of the subject individual; or 

2) where its disclosure is permitted under §5b.9 of the regulation.

(b) Permit unauthorized individuals to be present in controlled areas. Any unauthorized individuals observed in controlled areas 

shall be reported to a supervisor or to the guard force. 

(c) Knowingly or willfully take action which might subject the Department to civil liability.

(d) Make any arrangements for the design development, or operation of any system of records without making reasonable 

effort to provide that the system can be maintained in accordance with the Act and regulation.

Contracting Officers. 

In addition to any applicable provisions set forth above, those employees whose official duties involve entering into contracts on behalf 

of the Department shall also be governed by the following provisions:

1. Contracts for design, or development of systems and equipment. No contract for the design or development of a system of 

records, or for equipment to store, service or maintain a system of records shall be entered into unless the Contracting Officer 

has made reasonable effort to ensure that the product to be purchased is capable of being used without violation of the Act 

or regulation. Special attention shall be given to provision of physical safeguards.

2. Contracts for the operation of systems of records. A review by the Contracting Officer, in conjunction with other officials whom he 

feels appropriate, of all proposed contracts providing for the operation of systems of records shall be made prior to 

execution of the contracts to determine whether operation of the system of records is for the purpose of accomplishing a 

Department function. If a determination is made that the operation of the system is to accomplish a Department function, the 

Contracting Officer shall be responsible for including in the contract appropriate provisions to apply the provisions of the Act 

and regulation to the system, including prohibitions against improper release by the contractor, his employees, agents, or 

subcontractors.

3. Other service contracts. Contracting Officers entering into general service contracts shall be responsible for determining the 

appropriateness of including provisions in the contract to prevent potential misuse (inadvertent or otherwise) by employees, 

agents, or subcontractors of the contractor.

Rules Governing Responsible Department Officials. 

In addition to the requirements for Systems Employees, responsible Department officials shall:

1. Respond to all requests for notification of or access, disclosure, or amendment of records in a timely fashion inaccordance 

with the Act and regulation;

2. Make any amendment of records accurately and in a timely fashion;

3. Inform all persons whom the accounting records show have received copies of the record prior to the amendments ofthe 

correction; and

4. Associate any statement of disagreement with the disputed record, and

(a) Transmit a copy of the statement to all persons whom the accounting records show have received a copy ofthe 

disputed record, and

(b) Transmit that statement with any future disclosure.

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APPENDIX D. SAMPLE COST ACCOUNTING STANDARDS BOARD DISCLOSURE 

STATEMENT

COST ACOUNTING STANDARDS BOARD DISCLOSURE STATEMENT 

(REQUIRED BY PUBLIC LAW 100-679)

General Instructions

1. This Disclosure Statement has been designed to meet the requirements of Public Law 100-679, and persons 

completing it are to describe the contractor and its contract cost accounting practices. For complete 

regulations, instructions and timing requirements concerning submission of the Disclosure Statement, refer to 

Section 9903.202 of Chapter 99 Of Title 48 CFR (48 CFR 9903.202).

2. Part I of the Statement provides general information concerning each reporting unit (e.g., segment, Corporate 

or other intermediate level home office, or a business unit). Parts II through VII pertain to the types of costs 

generally incurred by the segment or business unit directly performing Federal contracts or similar cost 

objectives. Part VIII pertains to the types of costs that are generally incurred by a Home office and are 

allocated to one or more segments performing Federal contracts. For a definition of the term "home office", 

see 48 CFR 9904.403.

3. Each segment or business unit required to disclose its cost accounting practices should complete the Cover 

Sheet, the Certification, and Parts I through VII.

4. Each home office required to disclose its cost accounting practices for measuring, assigning and allocating its 

costs to segments performing Federal contracts or similar cost objectives shall complete the Cover Sheet, the 

Certification, Part I and Part VIII of the Disclosure Statement. Where a home office either establishes practices 

or procedures for the types of costs covered by Parts V, VI and VII, or incurs and then allocates these types of 

cost to its segments, the home office may complete Parts V, VI and VII to be included in the Disclosure 

Statement submitted by its segments. While a home office may have more than one segment submitting 

Disclosure Statements, only one Statement needs to be submitted to cover the home office operations.

5. The Statement must be signed by an authorized signatory of the reporting unit.

6. The Disclosure Statement should be answered by marking the appropriate line or inserting the applicable 

letter code which describes the segment's (reporting unit's) cost accounting practices.

7. A number of questions in this Statement may need narrative answers requiring more space than is provided. In 

such instances, the reporting unit should use the attached continuation sheet provided. The continuation sheet 

may be reproduced locally as needed. The number of the question involved should be indicated and the same 

coding required to answer the questions in the Statement should be used in presenting the answer on the 

continuation sheet. Continuation sheets should be inserted at the end of the pertinent Part of the Statement. 

On each continuation sheet, the reporting unit should enter the next sequential page number for that Part and, 

on the last continuation sheet used, the words "End of Part" should be inserted after the last entry.

8. Where the cost accounting practice being disclosed is clearly set forth in the contractor's existing written 

accounting policies and procedures, such documents may be cited on a continuation sheet and incorporated by 

reference at the option of the contractor. In such cases, the contractor should provide the date of issuance and 

effective date for each accounting policy and/or procedures document cited. Alternatively, copies of the 

relevant parts of such documents may be attached as appendices to the pertinent Disclosure Statement Part. 

Such continuation sheets and appendices should be labeled and cross-referenced with the applicable 

Disclosure Statement number and follow the page number specified in paragraph 7. Any supplementary 

comments needed to adequately describe the cost accounting practice being disclosed should also be 

provided.

9. Disclosure Statements must be amended when cost accounting practices are changed to comply with a new 

CAS or when practices are changed with or without knowledge of the Government (Also see 48 CFR 

9903.202-3).

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APPENDIX E. CONTRACT AUDIT WORKING GROUP AGENCIES AND OFFICES

AGENCY OFFICE OF RECORD POSITION OF RECORD

DCAA

DHS

DOE Office of Acquisition Management Field Assistance and Oversight Division, 

MA-621

DOI/IBC Acquisition Services Directorate Policy Division - Acquisition & Strategic 

Development 

DOT Office of the Secretary M-60

DOT/FAA Acquisition and Business Services Price/Cost Analysis Division

DOT/PHMSA Acquisition Services Division

DOT/VOLPE VOLPE Center

EDUC Office of the Chief Financial Officer Enterprise Procurement Initiatives

GSA

HHS ASFR

HHS/CMS Division of Financial Services OAGM

HHS/NIH Office of Acquisition Management and 

Policy 

Division of Financial Advisory Services 

Indirect Cost Branch

NASA/HQ Office of Procurement Contract Cost, Pricing, and Financing

PBGC Pension Benefit Guaranty Corporation Procurement Analyst

STATE A/LM/AQM/BOD/QA

TREAS Office of Financial Innovation and 

Transformation

Bureau of the Fiscal Service

SSA Office of Acquisition and Grants Acquisition Financial Service Audit 

Team

USAID M/OAA/CAS/CAM

OMB Office of Federal Procurement Policy

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OTHER RESOURCES

a. MAX.gov

b. Contractors can be found on GSA eLibrary

c. GSA Subject Matter Experts – ccas@gsa.gov

d. DCAA CHECKLISTS & TOOLS

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Thank you for your interest in the GSA Multiple Award Schedule SIN 541211Auditing 

Services. GSA is committed to delivering acquisition vehicles that provide Federal 

agencies with convenient access to the best qualified contractors in the professional 

services-based marketplace. If you have any questions regarding this Guide, or our 

program in general, please feel free to contact professionalservices@gsa.gov at any 

time.

For more information about Contract Audit Services, please visit our website at 

www.gsa.gov/schedules under the Professional Services Category or on the 

Acquisition Gateway.

Revised May 2023