ACO CORB EVALUATION EXAM UPDATED QUESTIONS AND
ANSWERS SURE A+
✔✔PBP Steps - ✔✔1. Identify PBP events (contractor proposed)
2. Establish completion criteria
3. Obtain/evaluate contractors expenditure profile
4. Establish event values
5. Determine the type of event: severable or cumulative
6. Incorporate PBP Arrangements into table/special provision
✔✔Criteria that should not be used for PBP's: - ✔✔• Signing of a contract or contract
modification
• Exercise of contract options
• The passage of time
• Attendance at meetings, conferences, seminars
• The expenditures of funds
• A surrogate for incurred costs
• Delivery of material, supplies or services via DD250
• Payment for cost-reimburseable line items
• Payment for goods or services
• Payment for partial deliveries
• An incentive arrangement
• Equal payment for each event/performance criteria
✔✔What is the difference between expiring vs canceling funds? - ✔✔Expiring Funds
can no longer be obligated but can be used to pay contractors
Canceled funds can no longer be obligated or paid
✔✔Expiring Funds - ✔✔can no longer be obligated but can be used to pay contractors
✔✔Canceling funds - ✔✔Canceled funds can no longer be obligated or paid
✔✔What are the ACO's responsibilities for PBP? - ✔✔1. Determine if PBP is practical
2. Limit recommendation of new/revised events to parameters express by PCO
3. At no time negotiate/establish finance terms without written concurrence of PCO
4. Determine adequacy of accounting system
5. Process PBPs promptly (within 14 days)
6. Ensure functional specialists who provide PBP support follow contract/FAR/DFARs
7. Ensure PBPs not submitted more frequently than monthly
8. Ensure MOCAS has sufficient funds under ACRN
✔✔There are a large number of physically complete FFP contracts, upon reviewing the
list of contracts some are showing ULO's and negative ULO's. What would you do?
Does this concern you? - ✔✔Yes this would concern me. FFP contracts should not
,have money remaining at physical completion. I would start by reviewing the list to see if
there is a common thread such as the same contractor. I would then start a data
integrity review. I would start by reviewing MOCAS and WAWF, checking to make sure
the contractor has submitted a final invoice and all invoices have been paid. I would
want to check that no invoice was incorrectly paid by DFAS, I would review MOCAS for
any clues to why a invoice hasn't paid. Reviewing codes that DFAS inputs. A SDW pull
would also assist in the invoice reconciliation. I would then start a modification
reconciliation. Checking for any modifications that weren't processed correctly in
MOCAS especially deobligation mods or mods that are removing work from the
contract. One additional resource I would check is IWMS to see if there is any
documents filed in the record that might assist in figuring out what the problem is.
✔✔Name 4 of the 6 Contractor Business Systems - ✔✔1. Accounting
2. Estimating
3. EVM
4. MMA (Material Management and Accounting System)
5. Property Management
6. Purchasing
✔✔Explain the timeline for business systems found to have significant deficiencies: -
✔✔a. 10 days for initial determination - attach unsigned draft Level III or IV CAR marked
draft, do not request CAP
b. 30 days for contractors response
c. 30 days for final determination - finalize the Level III or IV CAR in the CAR etool and
attach
d. 45 days for proposed CAP submittal
e. Within 90 days of notice of correction the AOC must request a review all significant
deficiencies
✔✔What are the ACO responsibilities regarding Business Systems? - ✔✔• Review
findings from functional specialists (BSAS) or auditor
• Prior to disapproving system, schedule CBS panel
• Implement payment withholds on contract only if the DFARS 252.242-7005
"Contractor Business System" and the specific business system clauses in contract
• Avoid taking withholds based on legacy determination unless contractor given due
process
• Ensure Contract Business Analysis Repository (CBAR) eTool is current, accurate and
complete at the prime contractor level
✔✔What should an acceptable CAP address? - ✔✔The cause of the significant
deficiency, including milestones to eliminate the deficiency with target dates for
implementation of the planned action, there should be clear and measureable goals
within the plan
✔✔What must be done prior to disapproval of a business system? - ✔✔• talk to F.S to
ensure understanding of findings
, • A higher level review by the HQ board of review
• ACO has the final decision
✔✔What is a Business System Analysis Summary (BSAS)? - ✔✔The BSAS is an
internal document that summarizes a contractor's business system determination and
identifies deficiencies. It should not be released to a contractor. It should not declare
significant/nonsignificant findings or recommend disapproval.
✔✔Within 90 days of receiving the contractors notification that the deficiencies have
been corrected, what must the contracting officer do? - ✔✔a. Ask the Auditor or F.S. to
determine if all cited significant deficiencies have been resolved
b. Promptly approve a previously disapproved system
c. Discontinue payment withholds (if applicable)
d. Close the Level III or IV car in the CMO CAR log
e. Change the status in the CBAR Etool
✔✔Under normal circumstances, what dollar value must a contract exceed in order to
apply a withhold? (FAR 30.604(i) & 30.605(i)) - ✔✔50 million, if the ACO believes it is
necessary to protect the Government's interest, they may implement withholds on
contracts less than $50M as long as they have the applicable business system clause
and 252.242-7005 with the approval of the Director or supervisor
✔✔What is the definition of significant findings? - ✔✔Significant findings means a
shortcoming in the system that materially affects the ability of the DoD to rely upon
information produced by the system that is need for management purposes. A level III
CAR should be issued. If non-significant, Level I or II CAR issued, but Business System
can still be approved.
It's a systemic problem throughout the entire system that makes the information
produced unreliable to the Federal Government.
Level III CAR requires, Board of Review Panel. Panel ensures consistency and findings
have been fully c
✔✔What is the risk when you have a disapproved business system? - ✔✔The risk of a
disapproved system is that neither the Government or the Contractor can rely on the
information being produced by the disapproved system. An example of a risk would be
regarding the property system disapproval. If a contractor is not adequately tracking
property purchased, the contractor could purchase the property twice, resulting in the
property being purchased twice, which could result in a contract overrun. If there are
deficiencies with estimating it could result in an over or underpriced contract which
could lead to not receiving the ordered product or the contractor going out of business.
Accounting risk is not having allowable, allocable or reasonable costs. Resulting in
unallowable costs being billed.
✔✔What are the four current Contractor Business System status options in CBAR
etool? - ✔✔Approved, Disapproved, not evaluated, and not applicable
ANSWERS SURE A+
✔✔PBP Steps - ✔✔1. Identify PBP events (contractor proposed)
2. Establish completion criteria
3. Obtain/evaluate contractors expenditure profile
4. Establish event values
5. Determine the type of event: severable or cumulative
6. Incorporate PBP Arrangements into table/special provision
✔✔Criteria that should not be used for PBP's: - ✔✔• Signing of a contract or contract
modification
• Exercise of contract options
• The passage of time
• Attendance at meetings, conferences, seminars
• The expenditures of funds
• A surrogate for incurred costs
• Delivery of material, supplies or services via DD250
• Payment for cost-reimburseable line items
• Payment for goods or services
• Payment for partial deliveries
• An incentive arrangement
• Equal payment for each event/performance criteria
✔✔What is the difference between expiring vs canceling funds? - ✔✔Expiring Funds
can no longer be obligated but can be used to pay contractors
Canceled funds can no longer be obligated or paid
✔✔Expiring Funds - ✔✔can no longer be obligated but can be used to pay contractors
✔✔Canceling funds - ✔✔Canceled funds can no longer be obligated or paid
✔✔What are the ACO's responsibilities for PBP? - ✔✔1. Determine if PBP is practical
2. Limit recommendation of new/revised events to parameters express by PCO
3. At no time negotiate/establish finance terms without written concurrence of PCO
4. Determine adequacy of accounting system
5. Process PBPs promptly (within 14 days)
6. Ensure functional specialists who provide PBP support follow contract/FAR/DFARs
7. Ensure PBPs not submitted more frequently than monthly
8. Ensure MOCAS has sufficient funds under ACRN
✔✔There are a large number of physically complete FFP contracts, upon reviewing the
list of contracts some are showing ULO's and negative ULO's. What would you do?
Does this concern you? - ✔✔Yes this would concern me. FFP contracts should not
,have money remaining at physical completion. I would start by reviewing the list to see if
there is a common thread such as the same contractor. I would then start a data
integrity review. I would start by reviewing MOCAS and WAWF, checking to make sure
the contractor has submitted a final invoice and all invoices have been paid. I would
want to check that no invoice was incorrectly paid by DFAS, I would review MOCAS for
any clues to why a invoice hasn't paid. Reviewing codes that DFAS inputs. A SDW pull
would also assist in the invoice reconciliation. I would then start a modification
reconciliation. Checking for any modifications that weren't processed correctly in
MOCAS especially deobligation mods or mods that are removing work from the
contract. One additional resource I would check is IWMS to see if there is any
documents filed in the record that might assist in figuring out what the problem is.
✔✔Name 4 of the 6 Contractor Business Systems - ✔✔1. Accounting
2. Estimating
3. EVM
4. MMA (Material Management and Accounting System)
5. Property Management
6. Purchasing
✔✔Explain the timeline for business systems found to have significant deficiencies: -
✔✔a. 10 days for initial determination - attach unsigned draft Level III or IV CAR marked
draft, do not request CAP
b. 30 days for contractors response
c. 30 days for final determination - finalize the Level III or IV CAR in the CAR etool and
attach
d. 45 days for proposed CAP submittal
e. Within 90 days of notice of correction the AOC must request a review all significant
deficiencies
✔✔What are the ACO responsibilities regarding Business Systems? - ✔✔• Review
findings from functional specialists (BSAS) or auditor
• Prior to disapproving system, schedule CBS panel
• Implement payment withholds on contract only if the DFARS 252.242-7005
"Contractor Business System" and the specific business system clauses in contract
• Avoid taking withholds based on legacy determination unless contractor given due
process
• Ensure Contract Business Analysis Repository (CBAR) eTool is current, accurate and
complete at the prime contractor level
✔✔What should an acceptable CAP address? - ✔✔The cause of the significant
deficiency, including milestones to eliminate the deficiency with target dates for
implementation of the planned action, there should be clear and measureable goals
within the plan
✔✔What must be done prior to disapproval of a business system? - ✔✔• talk to F.S to
ensure understanding of findings
, • A higher level review by the HQ board of review
• ACO has the final decision
✔✔What is a Business System Analysis Summary (BSAS)? - ✔✔The BSAS is an
internal document that summarizes a contractor's business system determination and
identifies deficiencies. It should not be released to a contractor. It should not declare
significant/nonsignificant findings or recommend disapproval.
✔✔Within 90 days of receiving the contractors notification that the deficiencies have
been corrected, what must the contracting officer do? - ✔✔a. Ask the Auditor or F.S. to
determine if all cited significant deficiencies have been resolved
b. Promptly approve a previously disapproved system
c. Discontinue payment withholds (if applicable)
d. Close the Level III or IV car in the CMO CAR log
e. Change the status in the CBAR Etool
✔✔Under normal circumstances, what dollar value must a contract exceed in order to
apply a withhold? (FAR 30.604(i) & 30.605(i)) - ✔✔50 million, if the ACO believes it is
necessary to protect the Government's interest, they may implement withholds on
contracts less than $50M as long as they have the applicable business system clause
and 252.242-7005 with the approval of the Director or supervisor
✔✔What is the definition of significant findings? - ✔✔Significant findings means a
shortcoming in the system that materially affects the ability of the DoD to rely upon
information produced by the system that is need for management purposes. A level III
CAR should be issued. If non-significant, Level I or II CAR issued, but Business System
can still be approved.
It's a systemic problem throughout the entire system that makes the information
produced unreliable to the Federal Government.
Level III CAR requires, Board of Review Panel. Panel ensures consistency and findings
have been fully c
✔✔What is the risk when you have a disapproved business system? - ✔✔The risk of a
disapproved system is that neither the Government or the Contractor can rely on the
information being produced by the disapproved system. An example of a risk would be
regarding the property system disapproval. If a contractor is not adequately tracking
property purchased, the contractor could purchase the property twice, resulting in the
property being purchased twice, which could result in a contract overrun. If there are
deficiencies with estimating it could result in an over or underpriced contract which
could lead to not receiving the ordered product or the contractor going out of business.
Accounting risk is not having allowable, allocable or reasonable costs. Resulting in
unallowable costs being billed.
✔✔What are the four current Contractor Business System status options in CBAR
etool? - ✔✔Approved, Disapproved, not evaluated, and not applicable
