AICPA Expresses Criteria Concerns on DoD Proposed Attestation Requirement

November 20, 2014

The American Institute of CPAs’ (AICPA) Governmental Audit Quality Center commented on a Department of Defense (DoD) Federal Acquisition Regulation Supplement (DFARS) Proposed Rule titled, Defense Federal Acquisition Regulation Supplement; Business Systems Compliance, which would establish a triennial CPA attestation engagement to ensure appropriate contractor accountability for adequate contractor business systems.  

The AICPA’s September 15 comment letter expresses a significant concern that the DFARS criteria to be used for the proposed attestation engagement may not be articulated using language that is sufficiently objective or measurable.  The letter also recommends that DoD assemble a working group comprised of representatives from DoD and key stakeholders, including the CPA profession, to further discuss the issues surrounding the proposed attestation engagement, including the need to establish objective and measurable business systems criteria. Other concerns, comments, and recommendations are also provided to DoD in the AICPA letter.