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Ensuring Compliance with Federal Contracts The Changing Landscape

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1 Ensuring Compliance with Federal Contracts The Changing Landscape
Tim A. Di Guiseppe

2 High-Visibility Procurement & Audit Issues
Impact on DCAA interaction with contractors after GAO reports No longer providing interim audit results Limits ability to take corrective actions before issuance of audit report No longer advising on how to remedy audit issues Recommendations limited to “correct it” – not how to correct Internal control audits are now limited to “Pass-Fail” No discussion on the significance of an internal control deficiency Eliminating Flexibility and Auditor Judgment Forces any and all audit observations into an audit report Protects DCAA from claims of failing to report audit issues

3 High-Visibility Procurement & Audit Issues
Business Ethics & Conduct and Mandatory Disclosure FAR subpart 3.10 Contractor Codes of Business Ethics and Conduct (COBEC) Any contract over $5 million – COBEC must be in place with appropriate training of personnel and adequate policy and procedures FAR subpart 9.4 Debarment, Suspension and Ineligibility Mandatory disclosure of certain violations to agency OIG fraud, civil false claims act , significant overpayments on government contracts Based on creditable evidence (not defined) In a timely manner (not defined) Any cited violation know by contractor up to three years after final payment Some OIGs have provided disclosure forms on their public websites

4 High-Visibility Procurement & Audit Issues
Contractor Financial and Management Internal Controls Financial and Management internal control audits More stringent application of audit procedures in assessing compliance with DCAA control objectives More audit findings deemed significant regardless of materiality DCAA audit guidance Internal control weakness that result in or could result in miss charging – reported as significant deficiencies and material weakness “Inadequate in Part” no longer allowed – Adequate / Inadequate only Inadequate – auditors to encourage CO to suspend a portion of billed costs Limited Scope Internal audit – If an internal control deficiency is found during non-internal control audits Must pursue a limited scope audit of the identified deficiency If proven – entire system could be deemed inadequate

5 High-Visibility Procurement & Audit Issues
Control Environment and Overall Accounting controls DCAA has often challenged “gaps” between contractor procedures and DCAA Internal Control Matrix, which include DCAA expansive and self-defined controls (not expressly stated in FAR) Expect DCAA to use the rewrite of FAR Part 3 and Part 9 to their advantage in citing contractor systems as inadequate

6 High-Visibility Procurement & Audit Issues
Billing Systems Based on what we have discuss so far, this functional system we believe will generate more audit attention going forward, with possible outcomes of disallowing/suspending billed costs, revocation of direct billing privileges, challenge of provisional indirect rates, and returned incurred cost proposals as inadequate. DCAA will focus on Contractor systems’ Ability to provide adequate and timely incurred cost submissions Adequacy of system for capturing unallowable costs Ability of system to ID overpayments and prompt return of funds Adequate tracking of actual incurred cost for flexibly-priced contracts Timely adjustments of invoices for year-end final indirect rates Adequacy of written procedures

7 High-Visibility Procurement & Audit Issues
Labor Charging and Timekeeping DCAA trends in challenging labor charging internal controls include: Employment of uncompensated overtime practices (salaried personnel), to include all employees regardless of materiality Use of highly-detailed work authorization forms, to include information ordinarily not captured on such forms (such as contract scope) Ability of contractor to identify changes in submitted time charges, especially within an electronic timekeeping environment Prompt employee certifications and submission of daily time charges , with the definition of “prompt’ at the auditor discretion Expectations that employees will know where the hotline posters are located as well as be able to confirm that the employee has been trained in COBEC

8 High-Visibility Procurement & Audit Issues
Pre-award and Post-award Accounting Systems Contractors not considered “major” are often subject to financial and cost accounting systems internal control audits. Areas of focus include: General practices of direct and indirect cost allocation Capturing unallowable cost Billing costs out of the system Accurately capturing cost by project Financial stability of the company regardless of size DCAA will consider written procedures as mandated for all cost accounting and contracting functions Contractors should revisit existing formal procedures before such audits Are they adequate Are all procedures formalized

9 High-Visibility Procurement & Audit Issues
Accounting for Unallowable Costs DCAA has appeared to embrace a much more narrow interpretation of FAR and the provisions incorporated from CAS 405 DCAA has shown a reluctance to accept less formal cost accounting systems for identification of unallowable incurred cost DCAA has deemed systems that do not have specific GL accounts for capturing unallowable cost as not compliant with FAR and CAS Contractor must be prepared to demonstrate their system is compliant Contractor need to become familiar with FAR which establishes guidelines for assessing penalties on unallowable indirect costs ( (a)), to ensure DCAA has properly followed the guidelines Which contracts are subject to penalties When waivers of penalties are mandated ( ) DCAA will continue to aggressively recommend penalties on unallowable cost.

10 High-Visibility Procurement & Audit Issues
Allowability of specific costs Organization Costs Unallowable under FAR – documentation is important Professional and Consulting fees While allowable FAR (f) requires adequate documentation such as Agreement Detail invoices Work products While FAR has a loose definition of documentation, DCAA sets it own higher standard, so be prepared Public Relations and Advertising High focus area for DCAA – triggers are Open house to general public Anything that looks and smells like a trade show Direct selling activities (allowable) where evening events/business meeting are conducted Any PR/advertising activity conducted during the time frame of a merger or acquisition

11 High-Visibility Procurement & Audit Issues
Allowability of specific costs (con’t) Business meeting and conferences A target of DCAA especially if there is a hint of recreation associated with the activity Employee business travel Viewed as a high risk are by DCAA Constraints in FAR add to the fun Must follow the FTR/JTR DCAA has tried to apply the constraints of FAR to consultants or subcontractors. The FAR is by no means clear on this issue Executive Compensation An area where DCAA likes to claim it survey proves such compensation as unreasonable While an annual salary ceiling is set by OFPP, DCAA evaluates work performed to salary in determining reasonableness – DCAA interpretation

12 High-Visibility Procurement & Audit Issues
Allowability of specific costs (con’t) Employee Bonuses Less likely to be challenged if awards are paid in accordance with a documented agreement (policy or plan), consistently followed and the amount of the awards are supported. Legal fees FAR – complex regulation – component must audited involve cost related to proceedings involving a government (federal, state, local, foreign) Depending on outcome, many cost may be unallowable If allowable under FAR (e)(3) recovery limited to 80%

13 High-Visibility Procurement & Audit Issues
Adequate and Timely Incurred Cost Proposals Proposals will be rejected under the following circumstances Not submitted within six months of year end Not prepared in sequenced schedule format or not inclusive of all schedules and data as identified in Chapter 6 of the DCAA Information for Contractors Pamphlet Include amounts which should but do not tie to other schedules Include any cost which appear to be unallowable Not submitted in electronic form Not certified as required by FAR

14 High-Visibility Procurement & Audit Issues
FAR Part 31 Reasonableness Criteria Based on experience, DCAA will continue to elevate the use of reasonableness as a basis for questioning incurred and billed costs and in passing judgment on a contractor’s accounting practices and related internal controls. Allocability Issues DCAA has shown a trend in applying CAS allocability provisions on non-CAS covered contractors (such as CAS 403 Home Office Allocation) DCAA often challenges Allocability of cost after the fact claiming that a different methodology is a better or best allocation No requirement to use the “best” allocation methodology, only that cost are reasonably assigned to cost objectives based upon causal and beneficial criteria

15 High-Visibility Procurement & Audit Issues
Resolution of Audit Issues The trend continues where DCAA does not provide any or sufficient data in writings that clearly defining the basis for questioned costs or inadequate internal controls, nor are contractors given sufficient time to evaluate and respond to audit findings Contractors are entitled to satisfactory explanations and ample opportunity to review and respond to audit challenges. Chapter 5 of the DCAM requires auditors to discuss audit issues and basis of their finding with the contractor

16 DCAA and Access to Contractor Records
DCAA reasserts and redefines its access to records an intentional disregard of the requirement in clause FAR Examples Request all data on code of conduct violations and consequences – not required under FAR (b)(3)(i) which cites specific violation that must be disclosed Request that contractors provide data on violations to DCAA and ACO within 5-10 days – The mandatory disclosure rules explicitly state that disclosure is to the Agency IG with a copy to the CO DCAA requests contractors furnish documentation to “verify that the external CPA does not provide accounting services to the contractor – This pertains to PCAOB Independence standards for which DCAA has no authority Available data should be provided to DCAA “upon request” and that DCAA have direct access to contractor employees – internal documents suggest 3 to 5 days Not supported by the FAR – particularly access to contractor employees

17 Proposed DFARS Rule: Withholding Payments to DoD contractors
Background Late 2008 FAR (mandatory disclosure) required contractors to disclose certain violations of law, Civil False Claims Act and significant overpayments DCAA made a fundamental shift away from cooperation with government contractors 2008 and 2009 DCAA audit guidance memoranda imposed rigorous New timelines for responding to audit request for records and access to contractor personnel Auditors could no longer find contractor “internal control systems” inadequate “in-Part” but must find the entire system inadequate and take action to suspend payment of invoices where a single control objectives was not met Established procedures to quickly escalate pressure on contractors who fail to immediately comply with records request or who denied auditors access to personnel “Brave New World” auditors exercise less discretion and demonstrate more “skepticism”

18 Proposed DFARS Rule: Withholding Payments to DoD contractors
Proposed Withholding Rule Defines six separate business systems and states that a CO “will immediately withhold ten percent of each of the contractor’s payments under this contract” based on the CO’s determination that any of those business systems is deficient, Accounting Systems Earned Value management Systems Estimating Systems Material Management and Accounting Systems Property Management Systems Purchasing Systems If a contractor submits an acceptable corrective action plan within 45 days of receipt of a CO’s notice of intent to withhold, but has not completed the corrective actions, the CO will reduce the withhold to 5% of each payment until the CO determines that the contractor has corrected the deficiencies

19 Proposed DFARS Rule: Withholding Payments to DoD contractors
Proposed Withholding Rule (cont) A CO may withhold payments for deficiencies in more than one business system, but the cumulative percentage of payments withheld is limited to 50% of contract payments. Nonetheless, if the CO determines that there are one or more system deficiencies that are “highly likely to lead to improper contract payments being made, or represent an unacceptable risk of loss to the Government” then the CO “will withhold up to 100% of payments” until the CO determines that the contractor has corrected the deficiencies.

20 Proposed DFARS Rule: Withholding Payments to DoD contractors
Summary COs allowed to withhold 10%, 50% or even 100% of Interim payments to contractors where the CO determines that a contractor’s “business systems” are deficient. Poses a significant business risk to DoD contractor of all sizes Continues a trend of increasing compliance burdens Contractors should Reevaluate the cost of compliance Review current business systems for potential deficiencies Make any identified corrections before being threatened with withholding of payments

21 Proposed DFARS Rule: Withholding Payments to DoD contractors
Recommendations Consider performing an external audit or other assessment of internal controls related to the business systems subject to the proposed rule Such exercises will allow contractors to address any potential weaknesses in advance of an audit, hopefully avoiding “inadequacies in business systems” Maintaining well-functioning business systems provide visibility over critical contract metrics and allows contractors to manage workload and costs Contractors must consider the increase risk and cost imposed by the proposed rule and make informed decisions about the business tools they invest in and the types of contracts for which they choose to compete

22 Contractor Business Systems and Internal Controls
The proposed DFARS rule on Payment withholds defined contractor business systems Will implement compliance enforcement mechanism Allows for withholding up to 100% of payments for deficiencies While the rule clearly assigns the decision making authority to the CO, they rely on DCAA to identify deficiencies The expectation for business systems is: Provides reasonable assurance of compliance to laws and regulations Data is reliable Risk of misallocation and mischarges of cost are minimized It fails to define any new measurable objective standards Except those already defined (e.g. MMAS inventory accuracy 95%)

23 Contractor Business Systems and Internal Controls
The Government views the withhold provision of the proposed rule as necessary because Despite DCAA interpretations, current regulations do not provide for administrative withholds for deficiencies As proposed, a contractor could find itself without payments based upon no actual mischarges or overbilling, but merely a deficiency which is “highly likely to lead to improper contract payments” If “highly Likely deficiencies” are found, one would think a moderately skilled auditor could find actual mischarges, thereby eliminating the need to impose withholdings based auditor’s interpretation of what qualifies as a “highly Likely deficiency”

24 Contractor Business Systems and Internal Controls
While FAR imposes internal control requirements on contracts in excess of $5 million and exempts small business The proposed DFARS rule does not set a dollar minimum or exempt small business Thereby imposing higher standards on DoD contractors than those imposed on civilian agency contractors There is significantly more to this propose rule than has been covered so far. We encourage contractors to read the propose rule. Go to search for DFARS

25 Ensuring a compliant cost accounting system
The changing environment in which DCAA conducts it system audits puts a contractor at greater risk of audit findings such as Improper allocation of costs to final cost objectives Questionable treatment of unallowable costs Questioned indirect rate structures Reasonableness of allowable and allocable costs Inadequate internal controls Non compliance with FAR and if applicable to CAS

26 Ensuring a compliant cost accounting system
How to reduce the risks Ensure your key employees have a through understanding of the rules as outlined in the FAR and CAS and how and which one apply to your business Obtain an understanding of what DCAA looks for in an Accounting Systems audit Refer to Chapter 5 of the DCAA audit manual, and Contractor Information section of the DCAA website Both can be found at Perform a self assessment of your accounting system, or Have an outside source perform a mock DCAA Accounting systems audit If your business is such that it is not cost effective to have full time staff with the skill levels necessary to perform the above steps, look to outside experts. The little bit of money spent on such experts could save you significant dollars in the future

27 Prime Contractor Management of Subcontractors
A significant shift in DCAA expectations for prime contractor compliance with FAR (e)(2) Primes are being held to a higher standard for “management” of subcontractors Shifting towards the prime auditing the subcontractor when an auditable subcontract is awarded Insisting that the prime flow down the same access to records clause ( ) to its subcontractors as applies to the prime The prime is to gain and document an understanding of a subcontractors accounting and billing system and to verify invoices to the subcontractor books and records Monitor subcontractors provisional billing rates and ensure timely submission of incurred cost proposals Internal Control Questionnaire – number of employees, direct and indirect headcount, segregation of unallowable costs, job cost reconciliation, billing internal controls, etc.

28 Prime Contractor Management of Subcontractors
While the FAR does not really answer the question of what is expected of the prime in managing subcontractors, DCAA is pushing the prime to ask for substantially more information and more access to subcontractor records. Subcontractors are being forced to decide if and how a prime will have access to its books and records Attributable to DCAA decision to reverse it long standing role with respect to audits of subcontractors

29 Prime Contractor Management of Subcontractors
Nothing in FAR suggest that the prime’s management of its subcontractors includes audits subject to Government auditing standards or generally accepted auditing standards FAR (e)(2) provides for only three exceptions in which the prime’s management role would be expanded (2) The prime contractor is responsible for managing its subcontracts. The CAO’s review of subcontracts is normally limited to evaluating the prime contractor’s management of the subcontracts (see Part 44). Therefore, supporting contract administration shall not be used for subcontracts unless -- (i) The Government otherwise would incur undue cost; (ii) Successful completion of the prime contract is threatened; or (iii) It is authorized under paragraph (f) of this section or elsewhere in this regulation.

30 Major Defense Acquisition Program and Technical Data Packages
DoD interim rule (effective 2/24/10) implements Section 202 of the Weapon Systems Acquisition Reform Act which requires all MDAP programs include measures to ensure competition or the option of competition, at prime and subcontract levels. The rule also requires that acquisition plans for MDAPs include measures that document the rational 1) for selection of subcontractor tier or tiers; 2) measures that will be used to ensure competition, or the option of competition

31 Major Defense Acquisition Program and Technical Data Packages
Measures to ensure competition or options for competition include such specific items as: Competitive prototyping, Dual-sourcing, Unbundling of contracts, Funding of next-generation prototype systems or subsystems, Use of open architecture to facilitate upgrades, Use of build-to-print approaches, Acquisition of complete technical data packages, Periodic competitions for subsystems upgrades, Licensing of additional suppliers, and Periodic system or program reviews addressing the competitive effects of program decisions

32 Major Defense Acquisition Program and Technical Data Packages
To ensure fair and objective “make-buy” decisions by prime contractors, contractors must: Give “full and fair consideration” to outside sources for the development of subsystems and components The rule also requires that: solicitations and contracts must provide for government surveillance and assessment of the process and the extent to which prime contractors gave “full and fair consideration” to all potential sources Source-of-repairs awards for maintenance and sustainment services on major weapons systems should be made on a competitive basis to the maximum extend practicable

33 Major Defense Acquisition Program and Technical Data Packages
What does this all mean The number and availability of MDAP related prime and subcontracts awards on “Sole Source or Limited Competition Basis” is likely to decrease, triggering increase overall competition DoD will increase its use of methods and strategies to increase competition, such as unbundling of contracts, use of open architecture, and dual sourcing DoD will also increase competition by requiring delivery of complete technical data packages. Contractors may find it increasingly difficult to withhold proprietary data or unduly restrict the DoD’s rights to data delivered under MDAP contracts Contractors will feel an increased burden to document and justify noncompetitive “make-buy” decisions that seem self-serving, such as a contractor’s decision not to source work to outside entities

34 How to Survive a DCAA Audit
Surviving a DCAA audit can be tricky if you do not take the necessary steps to ensure that you Understand the scope of the audit Manage the audit process Documentation Personnel Within Scope Respond appropriately to DCAA request Timely

35 How to Survive a DCAA Audit
What is a successful audit? Contractor and contractor systems are compliant with all appropriate regulations and statues A successful audit at a minimum meets the following criteria DCAA applies the audit procedures objectively The audit is conducted in accordance with the audit plan The company plans for support during the audit are appropriate The audit is fair and balance highlighting both positive and negative aspects of the audit subject DCAA audit findings are adequately documented and presented fairly and appropriately in the audit report, and DCAA audit process presents a minimum disruption to the contractor’s normal operations A successful audit = No Findings that significantly impact operations and finance

36 How to Survive a DCAA Audit
Surviving a audit means not standing by and letting it happen Plan head Understand the types of audit DCAA performs The types of audits and audit programs can be found at DCAA website Understand your status as a contractor Small, medium or large Are your contracts competitively awarded or negotiated or a mix Commercial item contracts Are your contracts Cost Accounting Standards (CAS) qualified Understanding your status as a contractor will help in planning for the types of audits you would be subject to

37 How to Survive a DCAA Audit
Once the types of audits your company is subject to have been identified, the planning process should include at a minimum the following steps Insist on an entrance conference What specific areas of the company’s financial or operational procedures and records are to be audited? Ensures that everyone understands the specific scope of the audit and agrees not to exceed it Insist that the auditor be specific so management can plan, prepare, and respond appropriately to the scope of the audit and the auditor’s request What approach does the auditor intend to use? Enables company management to begin compiling the required records Helps in understanding how the auditor intends to work, ensuring there will be no surprises Limited audit or full scope Sampling techniques or 100% transaction audit Rely on company assessment of inventory values or insist on observing in-process transactions and random physical counts These questions should be discussed in the entrance conference

38 How to Survive a DCAA Audit
Insist on an entrance conference (cont) Which company personnel need to be available? Advise functional managers and employees of the pending audit so they can be prepared and available as needed What is the timing of the audit? Knowing the length of the planned field work helps minimize interference with normal operations Other parameters? If there are unique issues about the organization or the proposed audit that could impact the audit, you should resolve them during the entrance conference. Offsite facilities or special access facilities Will the auditor use specialist to focus on one or more areas of audit Appoint an internal liaison Appoint a single point of contact Selecting and preparing the right individual for this job is one of the most important issues in controlling the success of audits and minimizing their impact on company operations

39 How to Survive a DCAA Audit
Appoint an internal liaison (cont) Responsibilities and goals Maintain a log of all information and documents provided to the auditor during the audit Purpose is to facilitate the audit process When the auditor needs access to people or documentation, the liaison informs the appropriate managers and staff that they need to make themselves available and that certain records and documents must be ready Attributes of successful internal liaisons Tenure within the organization and good overall understanding of operations Experience in several different departments An understanding of the products and/or services the company sells Exposure to, or experience with DCAA audits An appreciation for both the financial and the operational sides of the organization

40 How to Survive a DCAA Audit
Assemble the management Team Prevent surprises The management team plays a crucial role in a smooth audit Unprepared managers cause many serious audit problems Inform the managers of all affected departments about the nature of the audit Remind them to cooperate in all respects within company and regulatory policy, in a timely and responsive manner Inform the team of the agreed upon audit scope, and caution them to keep the audit within those bounds Coordinate Internally An effective way to streamline an audit is to tell managers and employees ahead of time how to prepare for the audit To minimize interruptions, managers should have the liaison schedule all meeting and request for documentation

41 How to Survive a DCAA Audit
Establish an accurate, accessible record-keeping system Know how to access documentation Once the audit approach is known, gather and organize the required records Establish and maintain a record keeping system that meets the needs of the organization and complies with the record retention requirements of the FAR Review section 4.7 of the FAR Covers the minimum retention requirements for certain types of documents and records Operating under the rules of compliance is one thing Organizing those records and making them accessible for the auditor is another Establish a record retention system that will meet audit objectives The focus of DCAA audits is on the final cost objective, which means they generally work from the contractual document back to individual transaction records. Record retention system should follow this path E.G., if you use a job cost system, you may want to group all records related to a particular contract

42 How to Survive a DCAA Audit
Be Responsive Maintain a positive relationship Through the liaison, provide requested information in a timely fashion, while allowing a reasonable time for function or department manager to gather the data When appointment are schedule with the auditor, be punctual and respond to questions in a clear and concise manner Ensure internal cooperation Be sensitive to conflicting responsibilities Supporting audits is not typical for most employees Managers may need to help employees handle their normal workload while they participate in the audit

43 How to Survive a DCAA Audit
Maintain a detailed log Here are some reasons why it is essential to maintain an accurate log of every document provided to the DCAA auditor The auditor may change his or her opinion upon review or lack of review of documentation The auditor may lose or temporarily misplace documents The auditor may not accurately account for the documents, and thus may claim non-receipt of an item The auditor may misinterpret information in documents It is important for management to know and understand what information the auditor relied upon in reaching the conclusions in his or her report Protect your interest Never give the auditor original documents, always copies

44 How to Survive a DCAA Audit
Do not allow the audit to exceed the agreed scope Control the audit process Use the following tips to control the audit scope in accordance with the plan you agreed on during the entrance conference The internal liaison should retain a list of the areas to be audited as outlined in the entrance conference If the auditor makes any request that appear to extend beyond the agree-upon scope, tactfully refer to the list If the auditor fails to work within the agree-upon scope, contact and discuss the issue with the auditor’s supervisor Avoid creating unnecessary documentation Do not develop documentation or analyses your company does not normally maintain, even if requested by the auditor. e.g. For example, suppose an auditor begins work on an issue related to the labor required to weld Product A, which is one of your companies products. The company normally only produces reports that indicate the total welding hours incurred by all weld shop employees for all components manufactured. The auditor questions whether the average hours in this report represents the average hours for Product A and request you to develop a report for Product A only. If your company does not ordinarily extract and analyze this information, you are under no obligation to create that information for the auditor

45 How to Survive a DCAA Audit
Insist on a list of required interviews Control access to company personnel Require a list from the auditor of employees to be interviewed Ensure the internal liaison is present at each interview and that a log is maintained of the relevant points discussed Manage spontaneous interviews A type of spontaneous interview is where the auditor venture onto the production floor to interview randomly-selected employees. Spontaneous audit procedures should still allow the internal liaison to coordinate with department managers so workers are minimally disrupted

46 How to Survive a DCAA Audit
Review the preliminary findings at the function/department level Functional/department representatives should have opportunities to discuss and respond to any conclusions the auditor has reached This is a two stage process Stage #1 Summarize findings – Once the auditor has reviewed a function, he/she should sit down with the functional manager and summarize the findings. This provides the manager the opportunity to review the summary and if necessary, question the auditor’s conclusions Stage #2 Prepare preliminary report – At the end of the audit, the auditor should prepare a preliminary report covering all of the findings resulting from the audit. This report provides a second opportunity for management to questions and discuss errors and provide written responses to the audit findings

47 How to Survive a DCAA Audit
Insist on an exit conference at the company level Review the preliminary audit report Insist on a thorough exit conference with the auditor and the auditor’s supervisor and the company’s audit management team to hear purported findings and ensure that they are consistent with the evidentiary documentation provided to the auditor Follow the routine An exit conference should be part of the standard routine of an audit. In fact, the DCAAM specifically states general procedures regarding the entrance and exit conference Read the audit report carefully Company management should take every opportunity to look at the written report, provide input based upon the observations and discussions during the audit and demand that the findings appear correctly Resolve inaccurate findings

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