During the desk audit, a CO examines the contractor’s AAP and Itemized Listing data to determine completeness or whether the contractor included all the required elements, and whether the Executive Order AAP and support data are acceptable. Part B of the SCER is used to report any problems in these elements. Before going on-site, the CO develops an On-Site Plan that reflects how the CO will address the identified problem areas during the on-site review.108
As part of the on-site review, COs must assess the contractor’s implementation of its AAP(s). Often, the entrance conference will include a discussion of unresolved AAP deficiencies, especially if the official responsible for preparing and implementing the AAP(s) is present. During this discussion, the CO also explains which aspects of the program are unacceptable and why they are unacceptable. The CO will also request that the contractor provide any additional information or documentation that the CO needs that the contractor did not provide before the on-site review.
108. See FCCM 2C03 – Onsite Plan.