19.  Multiple Compliance Regimes

Comment: The rule provides a different set of contractor business systems requirements for DoD and NASA contractors than are required for civilian contractors.

Response: The business systems criteria contained in the business systems clauses have been used in practice for several decades by Government personnel to assess the reliability and accuracy of management information produced by the applicable system. Because they are designed to be consistent with GAGAS, which are based on standards developed by the American Institute of Certified Public Accountants (AICPA), the system criteria are applicable equally to DoD, NASA, and civilian contractors.