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Tom Temin Sure, and there are also some updated thresholds for what gets audited, what gets investigated by the government, and also for some of the provisions for equipment and ancillary costs associated with a grant. Let’s talk about maybe the threshold for what gets audited. What are some of the top ones there? Dan Ramish Yes.
While OCI “requirements are applicable to most procurements, acquisitions below the simplified acquisition threshold (SAT) and those for commercial products are exempt, as well as subcontracts for commercial products or commercial services.” ” Use of “structural or behavioral barriers, internalcontrols, or both.”
The Final Rule also makes many changes to 2 CFR Parts 180 and 200, including, but not limited to, increasing the threshold for audits, clarifying the requirements for fixed amount awards, and implementing a mandatory disclosure rule.
Section 801 provides guidance on the “procurement policies, procedures, and internalcontrols” that must be followed to assure compliance with defense procurement requirements, particularly for a nondefense agency when it is performing an assisted acquisitions to procure supplies and services on behalf of the DoD.
31] Thus, implementing and documenting adequate internalcontrols for determining compensation can significantly reduce audit risk. However, the DCAM advises auditors that “top executive positions” are unique and must be audited individually regardless of the individual’s assignment to a job class, grade, or pay structure. [43]
Recently, TI Ukraine found an interim solution that combines the flexibility of ProBI with a low “entry threshold.” Nevertheless, organizations with the necessary resources have created several good solutions in ProBI, which we have incorporated into the public analytics module (e.g., “ Events in Lots ”).
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