NASA – Processing of Public Vouchers

Interim NASA rule, effective September 14, 2016, revising request for payments under public vouchers submitted under cost reimbursement contracts (https://www.federalregister.gov/documents/2016/09/14/2016-22046/nasa-federal-acquisition-regulation-supplement-revised-voucher-submission-and-payment-process-nfs).

As the DCAA is currently prohibited from performing audit services for non-DoD agencies under the provisions of the 2016 NDAA, NASA contractors are now required to submit public vouchers (electronically is preferred) directly to the NASA Shared Services Center (NSSC).

Takeaway – do not continue to submit vouchers to the DCAA as they will be rejected, and, as a result, payment will be delayed.

Background

This interim rule revises the NFS to implement revisions to the voucher submittal and payment process. These revisions are necessary due to section 893 of the National Defense Authorization Act for Fiscal Year 2016 (Pub. L. 114-92) prohibiting DCAA from performing audit work for non-Defense Agencies. Section 893 prohibits DCAA from performing audit work for non-Defense Agencies until DCAA’s backlog of incurred cost audits is below 18 months. DCAA’s current backlog of cost audits is greater than 18 months. NASA had delegated to DCAA the task of reviewing contractor requests for payment under its cost-type contracts. As a result of section 893, DCAA has ceased cost voucher audit support to NASA, in turn, jeopardizing timely payment to contractors for work performed. NASA has revised its cost voucher submission and payment process to ensure the continued prompt payment to its suppliers. Accordingly, the NFS needs to be immediately revised to implement procedural changes to minimize cost voucher submission and payment delays to NASA suppliers as well the potential accrual of Government interest payments to contractors.

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