When a company works with the Department of Energy, many times there is a feeling of "freedom" with respect to a government accounting system. By this I mean that since the Department of Energy does not have the DCAA to come out regularly to check the awardee's accounting system, the burden of compliance falls more directly on the awardee themselves. Many times, awards from the Department of Energy will specify in the contract or grant that the requirements of 10 C.F.R. § 600.316 apply. While this regulation does not specifically call out an audit per OMB Circular A133, there are a lot of references that the audit should "generally follow" the guidelines of A133. Since the A133 Audit was designed for non-profit organizations, it is really not appropriate to say that a full A133 audit is required. None the less, an audit to meet the 600.316 guidelines can be expensive, especially for a small business. Since the burden is on the awardee to pay for and have the audit performed, many times it is overlooked by the awardee and sometimes by the Department of Energy. I have seen recently where the Department of Energy has recognized this deficiency, albeit down the road a ways. The following are excerpts from an actual DOE letter to a grantee noticing problems as much as 7 years old!
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