The Defense Contract Management Agency (DCMA) reports that contract files contain insufficient documentation “across the board.”
DCMA regularly conducts reviews of each unit of the Department of Defense (DoD) that performs contracting functions. According to Claire M. Grady, who is DoD’s Director of Procurement and Acquisition Policy, “these reviews assess the effectiveness of the contracting function, analyze and assist in any problem areas, and identify noteworthy practices that may be beneficial to all organizations.”
On December 31, 2015, Grady’s office issued the results of the DCMA’s “procurement management reviews” for FY15. The report, in newsletter form, reveals that DCMA continues “to observe insufficient documentation across the board” in official contract files. The most common documentation flaws are:
- Lack of rationale for contract decision-making in instances of a contract modification, commercial item determinations, proposal evaluations, and contracting strategy, for example.
- Acquisition strategies aren’t linked to market research.
- Missing documentation due to over-reliance on electronic systems.
- Insufficient documentation of conversations leading to contract actions.
- Lack of documentation of GSA Schedule pricing compliance.
- Insufficient documentation that an independent government cost estimate (IGCE) provided the most appropriate basis for price comparison.
- Lack of documentation of work performed by Contracting Officer Representatives (CORs).
- Technical evaluation documentation not in alignment with solicitation evaluation criteria.
In addition to documentation deficiencies, DCMA notes that proposed prices were accepted without attempts to negotiate, thus representing “lost opportunities to save money or obtain better business deals.” The agency also found that annual reviews of COR files were not being conducted.
In a more positive vein, DCMA observed what it called “impressive” dedication by DoD’s contracting workforce and a “commitment to mission success.” They made note of leaders’ efforts to keep morale up and provide for training opportunities and well as electronic resources.
DCMA’s report also devotes attention to the unique challenge e-mails represent in documenting contract files. Because of the dominance of electronic communication, DCMA concedes that “the question of what should go into the official file is getting harder and harder to answer.” The agency recommends that “contracting personnel … do some critical thinking prior to putting e-mail correspondence into the file.” It recommends that the following questions be asked:
- Does the e-mail contain verbiage inappropriate for an official contract file?
- Does the e-mail provide a clear, succinct summary of the information for the contract file?
- If the e-mail represents a decision, is all necessary information to support that decision contained in the e-mail or is a memorandum more appropriate?
- Should a formal approval signature be obtained for that decision?
DCMA recommends that documentation should address both decisions and the rationale for each decisions. The full report can be accessed at: DCMA Procurement Management Review – FY15