The Defense Contract Audit Agency (DCAA) revised its guidance in the Contract Audit Manual to address the documentation requirements mandated by section 832 of the National Defense Authorization Act (NDAA) for Fiscal Year 2013, but implementation has been inconsistent. The revisions include provisions for DCAA auditors to document (1) that access to company internal audit reports is necessary to an ongoing DCAA audit, (2) the request sent to the company, and (3) the company’s response. However, based on GAO’s review of selected cases, implementing the changes has been inconsistent across the agency. GAO randomly selected eight requests for companies’ internal audits and compared them to the mandated requirements and DCAA instructions provided to its auditors as criteria to test whether or not the three documentation requirements had been properly recorded. None of eight cases sampled had complete records for the three required documents. The figure below shows the results of GAO’s examination of the eight requests.