Your offer, contract, modification request, and/or contract extension request may be subject to audit review by the VA Office of the Inspector General (OIG). The main object of the audit review process is to assist in achieving prudent contracting by verifying the sales, marketing, pricing, cost, and other data provided by the offeror to the assigned contract specialist.
Types of Audit Review Requests
- Pre-award audit requests seek to ensure that the information furnished by the offeror is accurate, complete, and current.
- Post-award requests of pre-award disclosures confirm the validity and quantity of the contract award.
- Post-award reviews are requested when the assigned contract specialist or VA FSS Service has indications of violations of the price reduction provisions, verification of voluntary disclosure data, and other related pricing violations (i.e. overbilling, compliance with the Trade Agreements Act, etc.)
The following criteria are followed when a contract specialist requests a pre-award audit review.
- When the estimated value of an offer or contract is expected to exceed the following dollar amounts:
$3,000,000 annually. For proposals and modifications submitted under the following Schedule programs:
- 65IIA Medical Equipment & Supplies
- 65IIC Dental Equipment & Supplies
- 65IIF Patient Mobility Devices
- 65VA X-Ray Equipment & Supplies
- 65VII Invitro Diagnostics, Reagents, Test Kits, & Test Sets
- 66III Cost-Per-Test, Clinical Laboratory Analyzer
- 621I Professional & Allied Healthcare Staffing Services
- 621II Medical Testing & Laboratory Services
$5,000,000 annually. For proposals and modifications submitted under the 65IB Drugs, Pharmaceuticals, and Hematology Related Products program.
- When an offer, including new solicitation proposals and product addition modification requests, with an estimated value of $500,000 or more is received from a reseller (any company that is not the manufacturer of the offered products) and does not have significant commercial sales and who will be representing their manufacturer’s information.
- When a VA Schedule contractor submits a request for modification to add products and/or increase prices on existing items and the estimated value of the request is expected to exceed the previously identified thresholds.
- When the estimated value of a contract extension is expected to exceed the previously identified thresholds.
Audit reviews can be requested at the discretion of the contract specialist. Requests for pre-award audits valued at less than the previously identified thresholds may be considered under special circumstances. To determine whether or not an audit review should be requested, the CS will consider the completeness/accuracy of the information provided; contractor’s past performance; the existence of extenuating or sensitive conditions; and/or the estimated value of the contract is so significant that an audit is warranted to protect the Government’s best interest.
The Review & Recommendations
The NAC and VA OIG reviewers seek to verify the accuracy of all CSP (Commercial Sales Practice) disclosures; make pricing recommendations to the requesting contract specialist; make tracking customer recommendations to the CS; and support the CS throughout negotiations (if applicable).
The current timeline for completion of a pre-award review by the assigned OIG auditor is within 60 working days of receiving the request from the FSS contract specialist.
Contact the FSS Help Desk for additional information on the VA OIG review process.
You can also contact your local Procurement Technical Assistance Center (PTAC). The PTAC offers assistance in preparing proposals, modifications, and contracts for audit review.