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The Internal Control Gaps Government Contractors Do Not Notice Until an Audit 

Posted by Neena Shukla in Government Contracting.

Key points covered in this article:

  • Internal control gaps often arise from gradual “drift” as businesses grow, with processes and oversight becoming less defined over time.
  • Common audit findings include issues with segregation of duties, unclear review controls, and outdated system access permissions.
  • Contractors who regularly revisit and document their controls are better prepared for audits, reducing surprises and aligning processes with current operations.

 

There is a moment that often occurs in audit kick-off meetings. The mood is calm, the coffee is still hot, and someone says, usually with genuine confidence, “Our internal controls are pretty solid.”  

Most of the time, they are not wrong. 

The issue is not that controls are missing or ignored. It is that they have quietly drifted. And audits have an annoying habit of noticing things that no longer look quite as they did when everyone assumed they did.  

Internal control findings rarely come from reckless behavior. They come from growth, familiarity, and the natural evolution of a business that has been busy doing actual work.  

Why Control Issues Are So Easy to Miss

Internal controls do not usually fail in obvious ways. They do not announce themselves. They age.  

What worked perfectly when a company was smaller often keeps running on autopilot as revenue grows, teams expand, and responsibilities shift. People take on more roles. Processes become more informal. Oversight still happens, but it looks different than it did a few years ago.  

From the inside, everything feels reasonable. From the outside, particularly during an audit, that same setup can raise questions no one has had to answer out loud before.  

Where Auditors Tend to Start Asking More Questions

One common area is segregation of duties. Early on, it is normal for a small group of trusted employees to handle multiple parts of a process. As the organization grows, that arrangement often stays in place longer than anyone realizes. Not because it is hidden, but because it is familiar.  

Another area is review controls. Many companies regularly review financial information. The issue is not whether someone looks at it, but how clearly that review is defined. What exactly is being reviewed? What would trigger a follow-up? And how would anyone know, six months later, that the review actually happened?  

System access is another quiet one. Permissions get added during busy periods and are not always revisited. Over time, people accumulate access that made sense once but no longer aligns with their role. It is rarely intentional. It is just something no one circles back to until an auditor starts asking who can do what, and how that access still makes sense today. 

 Day to day, none of this feels especially dramatic. These arrangements work well enough in practice. It’s usually only when someone new steps in and asks a few very straightforward questions that the gaps become easier to see. 

Most contractors would say they have strong management oversight, and that is usually not an unreasonable view. Oversight happens through a mix of conversations, emails, and a general sense of how things are going. In day-to-day operations, that approach often works just fine. 

Where it becomes more complicated is in an audit setting. Auditors are not trying to assess intent or second-guess judgment. They are trying to understand what actually happened, how it was reviewed, and how someone else would be able to see that same oversight after the fact. 

Not because auditors distrust management, but because the process requires clarity. What was reviewed, when it was reviewed, and what would have happened if something had gone wrong are questions that need answers grounded in something more tangible than memory.  

This is often the point where companies realize their controls exist more clearly in practice than on paper. 

Audits tend to slow things down in a way normal operations rarely allow. People are asked to walk through processes step by step, sometimes explaining actions they usually take without much thought. That shift alone can bring certain gaps to the surface, not because anything new has gone wrong, but because routines that usually run quietly in the background have to be described out loud. 

When that happens, some assumptions start to feel less solid than they did before. Processes that seemed clear in practice can look less defined when examined more closely. For growing government contractors, that moment can be uncomfortable, but it is often where the most useful conversations begin, particularly around whether controls still reflect how the business actually operates. It shows where controls have not quite kept pace with how the business now operates. 

Contractors that move through audits with fewer surprises are not necessarily more complex or more formal. What tends to set them apart is how deliberately they revisit their processes over time. Controls are looked at again after periods of growth or change, rather than being left untouched because they have worked in the past. 

Oversight still happens in very practical ways, but it is easier to follow. Reviews are documented in a way that lines up with what actually takes place, rather than what a policy might have described years ago. The result is not perfection, but a clearer line between how work is done and how it can be demonstrated when questions are asked. Controls are treated as living processes, not static requirements that were checked off years ago and left alone.  

That mindset does not eliminate findings entirely, but it does reduce the number that come as a surprise.  

 A Final Thought

Internal controls do not usually break overnight. They drift, quietly and gradually, while everyone is focused on running the business.  

Audits do not cause that drift. They simply notice it.  

For government contractors the real advantage is not having perfect controls. It is recognizing when familiar processes need to be looked at again and being willing to do that before an auditor has to ask.  

Internal control issues rarely come from neglect. They come from drift. To make it easier to spot that drift early, we have put together a short audit-readiness checklist for government contractors. It is intended to prompt reflection, not perfection. 

Access the checklist here

For guidance on how to prepare your organization, contact Neena ShuklaGovernment Contracting Team Leader, at PBMares.


Be sure to consult with your financial or tax advisor on this topic as individual situations may vary. The information contained in this article or webinar, and any related materials, are for informational purposes only, and cannot be relied upon for legal, financial, tax, accounting, or other professional services advice. The content is provided on an “as is” basis and PBMares makes no representations or warranties about the accuracy or sustainability of any information for your purposes. For any specific questions you may have, please contact us.

This content is accurate at the time of publication. Always ensure you are reviewing the most recent information available. Contact your tax or financial advisor if you need clarification.

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About the Author

Neena Shukla
Neena Shukla

CPA, CFE, CGMA, FCPA, CTP
Partner, Government Contracting Team Leader
Fairfax

Neena brings extensive experience leading and managing assurance and consulting engagements, with a deep background advising on SEC compliance, mergers and acquisitions due diligence, revenue recognition, stock compensation, employee benefit plan audits, cybersecurity, fraud and forensic accounting.

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