The Gormley Group’s Contract Compliance Risk Analysis

Jun 26, 2020


The best way to make sure your company is prepared is to conduct regular self-audits.  Not only do these identify potential trouble areas, they demonstrate responsibility.  Both factors can be key in eliminating or containing any problems that are discovered.

The Gormley Group’s Contract Compliance Risk Analysis services are designed for organizations that are looking to identify potential GSA or VA contract compliance risks and outline ways to minimize exposure to compliance requirements.  The Gormley Group (TGG) will review your Multiple Award Schedule to ascertain how it is managed within your organization.  TGG will:

  • Review and analyze your Schedule contract to identify risks of non-compliance. Particular areas of focus are:
    • Basis of Award Customers (BoA)
    • Potential price reductions issues
      • Review price/discount relationship with BoA
    • Ambiguities in contract terms that could lead to contract compliance issues
    • On-site -vs- off site rates
    • Automated monitoring of all compliance triggers
  • Review your processes for obtaining on-line access to records in the event of an IOA compliance assessment and/or OIG audit
  • Review of processes established to manage the schedule contract including procedures for
    • Receiving orders,
    • Invoicing,
    • Payment of the Industrial Funding Fee
    • Trade Agreements Act compliance
  • Review of GSA task orders to determine if work was done within contract scope
  • Review of client’s organizational structure for managing the schedule contract
    • Level of backup to digital signature process
  • Review of Management Structure

Additionally, are you prepared for COVID 19 and the unique and enduring challenges to business operations and mission fulfillment it presents?

On March 30, DOD issued extensive guidance on requests for equitable adjustment and utilization of existing FAR and DFAR procedures for COVID-19 claims and disputes. The CARES Act also appointed significant oversight resources- a special inspector general for pandemic spending, as well as a Congressional oversight board. These oversight groups will undoubtedly reinforce existing DCAA and DCMA scrutiny over incurred cost audits for COVID-19 work.

Including COVID 19 business practices to your compliance program is essential.  Practices such as monitoring:

  • Temporary exemption from TAA Compliance
  • Compliance with Payroll Protection Plan requirements (SAM reporting and forgiveness applications)

For more information regarding The Gormley Group’s Contract Compliance Risk Analysis Service contact or call 202.833.1120.

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