22.  DCAA/DCMA Internal Policies

Comment: By allowing DCMA/DCAA to determine the criteria by which contractor business systems will be measured through their internal policies and procedures, it should make those internal policies and procedures subject to the OFPP Act public comment process.

Response: This rule does not contain references to DCAA/DCMA internal policies to determine the criteria by which contractor business systems will be measured. Rather, as defined in each of the individual business system clauses in the rule, the definition of an acceptable system means a system that complies with the system criteria set forth in each clause, which have been published for public comment.