From Attestation Reviews To Examinations: The GSA OIG Expands The Scope Of Its Pre-Award Audits

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So there I was, just sitting there minding my own business. It was the third day of the GSA OIG's site visit being conducted as part of a routine pre-award audit (or as the OIG called it, a pre-award “attestation review”), and all was going well. The auditor, who was quite a nice guy frankly, had had many questions, as was to be expected, but nothing for which this particular mid-sized GSA Schedule contractor did not have a reasonable response. No Price Reductions Clause violations. No overbillings. No resume qualification issues. Overall, a pretty darn good preliminary report if you ask me. But then, out of the blue, he says, “okay, I'd like to interview your personnel now.” Interview my personnel?! Come again!?

I've worked with GSA Schedule contractors for years, have been through countless audits and investigations, and this was the first time ever the OIG had requested to interview my client?s personnel in the context of a pre-award audit. “Why?” I asked. “It's a new element of our standard pre-award audit program,” the auditor responded. “We're conducting 'examinations' now. Other agencies have been doing it for years.” Not recalling the memo advising that the OIG was moving from Attestation Reviews to Examinations (and frankly not even really understanding the difference between the two), I figured I probably should make some calls and do some reading. We agreed to table the issue of his interviews until a future meeting.

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Sheppard Mullin Richter & Hampton LLP on:

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