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Defense Contract Audit Agency (DCAA) Independent Public Accountant Program

Outsourced Pentagon audits return $0.35 per dollar. In-house: $2.38.

Summary

Congress ordered the Defense Contract Audit Agency to bring in private accounting firms to help eliminate a backlog of incurred-cost audits on defense contracts. A May 2025 GAO report found DCAA had actually eliminated the backlog itself, before the outsourcing program scaled up -- and that the audits it now outsources return far less per dollar spent than the ones it keeps in-house. A separate Defense Department Inspector General review, sampling one audit from every contracted accounting firm, found 11 of 16 outsourced audits violated government auditing standards, including 8 where the government may never know whether $940 million in contractor costs was legitimate. DCAA disagrees with every recommendation to fix it.

By Marcus Aurelius · July 12, 2026

In 2017, Congress ordered the Defense Contract Audit Agency () to start using private-sector "independent public accountants" to eliminate a backlog of incurred-cost audits -- the audits that determine whether a defense contractor's claimed costs are legitimate before the government pays out or closes a contract. A May 2025 GAO report found had actually eliminated the backlog itself, through a new risk-based sampling method, before the outsourcing program's first audits were even completed in 2020 -- and that the outside audits now relies on for a fifth of its incurred-cost workload return $0.35 for every dollar spent, versus $2.38 for the audits 's own auditors perform. A January 2025 Defense Department Inspector General review, sampling one audit from every one of the nine firms under contract, found 11 of 16 audits violated government auditing standards -- including 8 where the government may never know whether $940 million in contractor costs was ever properly examined. disagrees with every recommendation both reports make.

A backlog that was already gone before the outsourcing began

audits the costs defense contractors claim on cost-type contracts -- confirming they're allowable, allocable, and reasonable before a contracting officer can close the contract out. By fiscal year 2011, that workload had piled up into a backlog of roughly 21,000 incurred-cost audits, some based on cost proposals dating to 1996. Section 803 of the 2018 National Defense Authorization Act ordered to use qualified private accounting firms -- independent public accountants -- to help clear the backlog, complete audits within a year, and maintain what the law called "an appropriate mix of government and private sector capacity." submitted a plan to Congress in October 2018 projecting these firms would handle 100 audits a year in fiscal years 2019-2020, rising to 200 a year covering an estimated $16.5 billion in contractor costs annually by 2021-2025.

None of that materialized the way it was planned, largely because it wasn't needed the way it was planned. had already eliminated its incurred-cost backlog by the end of fiscal year 2018 -- before independent public accountants completed their first audit in 2020 -- crediting a new risk-based sampling methodology that sharply cut the number of proposals requiring any audit at all. From fiscal years 2020 through 2023, the outside firms completed just 99 to 136 audits a year: 485 of 's 2,408 total incurred-cost audits, about a fifth of the workload, covering $6 billion to $10.7 billion annually -- well short of the original plan's $16.5 billion target.

One in five incurred cost audits now goes to an outside firm
Incurred cost audits completed, DCAA auditors vs. independent public accountants, fiscal years 2020-2023 combined
DCAA-led incurred cost audits
1,923
Independent public accountant-led incurred cost audits
485
Source: GAO-25-107558, Figure 1
View data as table
Total incurred cost audits completed FY2020-2023, by auditor type
DCAA-led incurred cost audits1,923
Independent public accountant-led incurred cost audits485

's own auditor workforce shrank from 4,148 in fiscal year 2018 to 3,504 in 2023, and officials say the outside firms have freed auditors to focus on more complex reviews -- business-system audits, for instance, rose from under 300 completed a year in 2018-2019 to a peak of 650 in 2022. But despite that shrinking workforce and a program that's fallen well short of its own 2018 plan, has never formally reassessed how much of this work it should keep outsourcing, nor updated Congress on its plans, as the 2018 law also required. The Pentagon has agreed to finally deliver that assessment -- by April 30, 2026.

What the outsourcing has actually bought shows up starkest in 's own return-on-investment math. estimates that from fiscal years 2020 through 2023, its own auditors' incurred-cost work averaged $384,731 per audit and returned $2.38 in recovered costs for every dollar spent conducting it. The independent public accountants' audits averaged a much cheaper $45,257 per audit -- but returned just $0.35 per dollar spent, under a seventh of 's own rate. reviewed 's methodology and found the estimates reliable, with one caveat: 's own auditors generally handle the highest-risk, most complex audits, including on-site work at major contractors, so the comparison isn't apples-to-apples. Even so, a program built in part to save the government money is, by 's own accounting, returning dramatically less of it per dollar than the work it was supposed to supplement.

The auditors DCAA brought in to help pay for themselves returned 15 cents on the dollar less than a third as much
Estimated return on investment per dollar spent on incurred cost audits, fiscal years 2020-2023 average
DCAA-led incurred cost audits (return per $1 spent)
2.4
Independent public accountant-led audits (return per $1 spent)
0.4
Source: GAO-25-107558, Table 3 (Appendix I)
View data as table
Average estimated return on investment per dollar spent, DCAA-led vs. independent public accountant-led incurred cost audits, FY2020-2023
DCAA-led incurred cost audits (return per $1 spent)2.4
Independent public accountant-led audits (return per $1 spent)0.4
Average return on investment per dollar DCAA spent on its own incurred cost audits, versus outside accounting firms it pays to do the same work
$2.38 vs. $0.35
DCAA's own auditors recovered nearly 7 times more per dollar spent than the independent public accountants brought in to help
Sampled incurred-cost audits by outside accounting firms that DoD's inspector general found violated government auditing standards
11 of 16
34 total instances of noncompliance -- insufficient evidence, insufficient sampling, inadequate documentation, and skipped management inquiries -- across audits from a firm-by-firm cross-section of all nine contracted auditors
Potential unallowable DoD contractor costs represented in the 8 audits where outside auditors lacked sufficient evidence for their conclusions
$940M
those same 8 audits collectively questioned just $464,000 out of $2.88 billion examined -- a combined questioned-cost rate of 0.016 percent

What checking one audit from every contracted firm actually turned up

's report cites, but doesn't independently verify, a separate review that tested a more basic question than return on investment: are these outside audits even competent? The Defense Department's own Inspector General pulled a sample of 16 incurred-cost audits from a universe of 369 completed between October 2018 and September 2022 -- one audit from each of the nine contracted firms, deliberately chosen for the combination auditors should find suspicious: high dollar amounts examined, but almost nothing questioned. Eleven of the 16 -- 69 percent -- violated government auditing standards, with 34 separate instances of noncompliance across them: insufficient evidence to support conclusions in 8 audits, an insufficient sample methodology in 4, inadequate documentation of the work performed in 11, and missing required inquiries into contractor management about prior findings or pending legal proceedings in 11.

Every one of the 11 flawed audits was missing paperwork or a phone call, not just a number
Categories of noncompliance with government auditing standards found across DoD IG's 11 flagged audits
Insufficient evidence for conclusions
8
Insufficient sample methodology
4
Inadequate documentation of work performed
11
Missing required management inquiries
11
Source: DODIG-2025-062, Appendix C, Table 3
View data as table
Number of the 16 sampled audits with each category of noncompliance (audits could have more than one)
Insufficient evidence for conclusions8
Insufficient sample methodology4
Inadequate documentation of work performed11
Missing required management inquiries11

The specific lapses read like a checklist of what an audit is supposed to prevent. In one case, an auditor signed off on $1.4 million in equipment-rental costs without invoices or journal entries detailed enough to show the equipment was actually used on the contracts being billed. In another, an auditor accepted $92 million in direct labor costs as reasonable based only on confirming that timesheets were signed -- never comparing the pay rates to salary surveys or labor agreements, the way FAR guidance contemplates. In a third, had previously questioned $2.7 million in labor costs at the same contractor because the employees didn't meet the contract's labor qualifications -- and the outside auditor never asked whether that problem had been fixed. In a fourth, an auditor sampled from a $1.9 million subset of computing costs while the contractor's actual proposal claimed $5 million, without ever explaining in the workpapers why two-thirds of the claimed costs were excluded from testing. And in a fifth, an auditor set a $14 million materiality threshold for the whole audit, then applied that same threshold to a $358,100 travel-cost line item -- a test built to catch nothing, applied to a category too small for it to ever catch anything.

Add up the dollars behind just the 8 audits where evidence was ruled insufficient, and the government examined $2.88 billion in contractor costs through them -- and questioned a combined $464,000, or 0.016 percent, an amount so small it comes entirely from the 3 of those 8 audits that questioned anything at all. The Inspector General's own estimate of what might be hiding inside that gap: up to $940 million in DoD contractor costs the government can't actually vouch for, because the auditors paid to check them didn't gather enough evidence to know either way.

disputes essentially all of it. Of the eight audits flagged for insufficient evidence, says the Inspector General never proved five actually lacked it, and that the other three had documentation gaps -- not evidence gaps. 's central defense of the whole program: the sample covered only 4.3 percent of the 369-audit universe and found noncompliance in just 1.7 percent of workpapers, making this a non-issue rather than a systemic one. The Inspector General's counter: its risk-based sample, while only 4.3 percent of audits by count, covered 35 percent of the dollars examined across the full universe -- and workpapers include large volumes of material that were never the basis for an auditor's conclusions in the first place, meaning 's 1.7 percent figure measures the wrong denominator. All four of the Inspector General's recommendations -- to determine whether the eight flawed reports should be rescinded, to give 's own contract monitors explicit authority to check compliance, to require the outside firms to document how they'll meet auditing standards, and to add auditing-standards questions to 's own review checklists -- remain listed as unresolved. and the Defense Logistics Agency disagreed with all of them.

The takeaway

  • The assumption behind outsourcing these audits -- that private accounting firms would supplement 's capacity at comparable value -- doesn't survive 's own numbers. The outside audits return $0.35 per dollar spent versus $2.38 for 's own work, and has never formally reassessed whether that trade is still worth making, eight years after the program's original plan.
  • A sample built specifically to test the riskiest-looking audits -- high costs examined, low costs questioned -- found violations in more than two-thirds of them. Eleven of 16 audits failed to meet basic auditing standards, and the government's own account of what that could mean puts up to $940 million in contractor costs beyond verification, against just $464,000 actually questioned in those same audits.
  • disputes the individual findings, not just their scope. For 5 of the 8 audits flagged for insufficient evidence -- including the $92 million labor-cost example -- argues the auditors' evidence was adequate all along, not merely that any shortfall is too small to matter. With all four recommendations still unresolved and no independent verification of 's own rebuttal, the dispute is exactly where 's separate finding leaves it: unresolved, and without a plan.

Program-wide usage, cost, and return-on-investment figures are from -25-107558, 'Defense Contract Audit Agency: Formal Assessment Needed to Determine Future Use of Independent Public Accountants' (May 19, 2025), which cites but does not independently verify the DoD Inspector General's findings. The audit-compliance findings and specific examples are from a separate, earlier document: Department of Defense Office of Inspector General report DODIG-2025-062, 'Evaluation of Incurred Cost Audits Performed by Non-Federal Auditors for Compliance with Government Auditing Standards' (January 21, 2025), including its recorded dispute with and the Defense Logistics Agency. Both were read directly. The two documents examine different facets of the same outsourcing program -- a systemwide value assessment and a compliance audit of a risk-targeted sample -- and no figure from one document is treated as confirming a figure in the other unless both are cited.

Sources(2) ▾
  • U.S. Government Accountability Office, Defense Contract Audit Agency: Formal Assessment Needed to Determine Future Use of Independent Public Accountants (2025-05-19)Tier 1 primary official document (). Direct download confirmed via files.gao.gov mirror (HTTP 200); the canonical www.gao.gov URL used here is the correct citation URL and matches the Wayback-indexed address, though it returns HTTP 403 to non-browser clients. gao.gov · original document
  • Department of Defense, Office of Inspector General, Evaluation of Incurred Cost Audits Performed by Non-Federal Auditors for Compliance with Government Auditing Standards (2025-01-21)Tier 1 primary official document (DoD ), cited via its oversight.gov mirror since dodig.mil blocks non-browser clients. Directly reachable, HTTP 200. oversight.gov · original document
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