Requirement Removed From the Latest OASIS Draft RFP.

GSA has now announced that although a DCAA audited accounting system is no longer a pass/fail requirement, the DCAA has come on board to conduct “pre-award surveys of the accounting systems for apparent successful Offerors.”

When the first version draft OASIS RFP was released there was one requirement we felt would be limiting to Small Businesses — the requirement that all Offerors must have a DCAA audited accounting system to qualify. The Defense Contract Audit Agency (DCAA) is a Government agency that provides audit and financial advisory services to other Government agencies.

Before your accounting system is audited by DCAA you are required to gather a lot of documentation to prove your accounting controls are compliant with the requirements of time & material and cost accounting. The auditor will have access to both your internal and external accounting programs.  This is quite an investment of time and resources and the entire process can take months to finish. For more information on the audit process, check out the resource links below.

Due to the time and cost constraints of a DCAA audited accounting system, we believed  this requirement would have severely limited the number of small businesses who would have been able to participate in OASIS. Our concerns  must have been consistent with many others  given that when the revised version of the draft RFP was released, GSA announced that they were removing the pass/fail requirement of a DCAA audited accounting system.  GSA was still going to award extra points to Offerors that had a DCAA audited accounting system and  Offerors would still be obligated to have an accounting system that met the FAR requirements.  The accounting system must have been audited by either a cognizant non-DCAA government auditor or an independent auditor, but it no longer had to be DCAA audited.

GSA Circling Back Around

GSA has now taken another approach that ultimately circles around to the beginning; they announced on July 3rd that DCAA will conduct a pre-award survey of “apparent successful Offerors” accounting systems and if DCAA determines the accounting system is acceptable, the Offeror will be eligible for award.  We encourage any submitting vendors to review the requirements list here (

Our team of GSA Consultants will continue to monitor updates to the OASIS Draft RFP.  If you have any questions on how this may affect you, don’t hesitate to contact us through our website or by email at

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