DATE: November 2, 2021

Class Deviation to Implement the Office of Inspector General's New Audit Strategy for Management and Operating Contracts

TO: HCAs/Procurement Directors/Contracting Officers FROM: Director Contract and Financial Assistance Policy Division Office of Policy Office of Acquisition Management

This Flash notifies stakeholders of a class deviation to implement the Office of Inspector General's new audit strategy for management and operating contracts.

The subject class deviation is attached. It does not apply to the National Nuclear Safety Administration.

The class deviation, among other things, replaces management and operating contractors’ obligation to submit a “Statement of Costs Incurred and Claimed” with an obligation to submit a “final indirect cost rate proposal.” (The former is a Cooperative Audit Strategy unique audit term; the latter is a Federal Acquisition Regulation audit term, sometimes referred to as an “incurred cost proposal.”) The class deviation has already been disseminated to affected Heads of Contracting Activities.

The Office of Inspector General will coordinate with affected programs regarding the timing of: the termination of their contractors’ obligation to submit a
Statement of Costs Incurred and Claimed; their contractors’ obligation to submit a final indirect cost rate (incurred cost) proposal; and related audit (and audit finding resolution) activities.

Contracting Officer Questions concerning this policy flash should be directed to the Contract and Financial Assistance Policy Division at DOE_oapmpolicy@hq.doe.gov