33.  Effectiveness of This Rule

Comment: The respondent indicated that the proposed payment withholding is not tailored reasonably to address the Department's intended goal of preventing unallowable and unreasonable costs and waste, fraud, and abuse and improving the effectiveness of DCAA and DCMA.

Response: As noted by the respondent, contractor business systems play an important role in preventing waste, fraud, and abuse. Significant systems deficiencies place a substantial resource burden on DCMA and DCAA due to the increased oversight needed to protect the interests of the Government. The rule provides contracting officers with an additional tool to mitigate the Government's risk while contractors correct business systems deficiencies. Reliable contractor business systems employ internal controls to prevent unallowable and unreasonable costs, as well as waste, fraud, and abuse. Additionally, it reduces burden on Government resources, thereby allowing DCMA and DCAA resources to be employed more effectively.