I've
done contract audits before and essentialiy it boils down to compliance with the contract
as well as applicable regulations and laws. Regardless of the reasons for non-
compliance, if you're out of compliance-that's it! Monies paid for items not in
compliance must be paid back. That's exactly how an auditor will look at this.
I've commented only on those areas where I felt your response was weak and an
argument could be made to counter their position. As far as the other items, I felt that
either your argument was sufficient (that doesn't mean they'll agree) or that I agree with
their position----based on the contract or regulations.
My Comments
/ e request that NI~;n~ issue the appropriate budget approval for these positiO;J
l $48,989 Based on 48CFRPart 31-205-6 (a)(3), it would be an unreasonable expectation
that such an extremely small company such as Computer Aided Surgery, Inc. be required
to have an "established compensation" plan. In such a situation, it is reasonable and fair
to expect compensatIOn to be base upon the "practice followed" as employee needs arise
which is what has occurred here. Consequently the $48,989 should be allo~
V3,238 This amount for education costs must be a wed based on the regulations cited
above as the "practice" which will now be followed.
-----------.
$14,196 This amount should be allowed as NIST
above.
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