Overview
It is important to know that the USG has entered into agreements for financial audit services with the following nations. Pursuant to these agreements, pricing/audit services are performed by the respective Host Nation's (HN) audit agency instead of DCMA (Defense Contract Management Agency) or DCAA (Defense Contract Audit Agency):
- Canada
- France
- Germany
- The Netherlands
- The United Kingdom
Requests for reciprocal pricing/financial audit services of foreign contractors/suppliers in the above nations are subject to the applicable Annex of the respective International Agreement signed at the Secretary/Minister of Defense level. These international agreements can be found at acq.osd.mil.
Certain major programs are also subject to cooperative agreements with various foreign nations (e.g. Evolved Sea Sparrow Missile). These cooperative agreements may contain provisions that influence proposal development and review. In some cases, existing program cooperative agreements require that each signatory nation's government, including nations other than those identified above, provide pricing/financial audit services on their respective participating contractors. It is important to understand these provisions and identify them in your requests. Additional detail regarding individual cooperative agreements can be accessed at their respective program offices.
Both types of agreements (Reciprocal and Cooperative) provide for reciprocal "no-cost" pricing/financial audit services regarding contractor proposals (including technical evaluations), and each country retains the right to review their nation's contractor proposals.
Working with foreign contractors and nations
Working in an environment with foreign contractors and foreign nations presents distinct challenges, including:
- Language barriers
- Data exchange incompatibilities
- Business and cultural differences
- Multiple time zones and varying work schedules
- Country clearance requirements prior to undertaking site visits in foreign countries
- Email size constraints
Foreign nation audit reports/work products
- Vary from nation to nation
- Are derived from using each foreign nation's local practices and methodologies
- Will not be provided in the same format or level of detail as a DCAA audit report or DCMA price analysis report
- Require considerable time to complete
Clarification of audit results can be requested from the assigned foreign nation auditor through the POCs listed in the request-process instructions below. Requestors are also encouraged to provide comment on the feedback questionnaire included in some nations' audit reports.
Plan ahead: based on historical data, audit reports should not be expected in less than 120 days from request, with some nations requiring greater timeframes.
Export controlled information
Requestors should be cognizant of Export Controlled Information (i.e. International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR)), as all Government personnel have the responsibility to safeguard US Export Controlled Information they may come in contact with during the performance of their official duties.
Specific to pricing/financial audit services, prime contractors have the responsibility to determine if pre-award proposals and supporting documentation contain Export Controlled Information before a request for HN pricing/financial audit services can be submitted. Financial audit services cannot be requested of a HN if the proposal contains Export Controlled Information and there are no current authorizations or exemptions granted by the prime contractor.
If the proposal and/or supporting documentation contains Export Controlled Information, requestors should coordinate with the prime contractor to answer the following questions:
- In the accomplishment of the scope of review requested, will HN representatives need access to Export Controlled Information?
- If Export Controlled Information needs to be accessed to perform the requested pricing/financial audit services, the following needs to be answered/documented:
- Is the HN authorized (or granted an exemption) to access the Export Controlled Information?
- If yes, a copy of the written authorization/exemption from the prime contractor's Export Controls Empowered Official must be provided with the complete request package.
For DCMA requestors, more detail on Export Controlled Information can be found within DCMA-MAN 2501-11, Section 10. For non-DCMA requestors, more detail can be found at the export control authority responsible for export controls on your program.