documentation | The Contracting Education Academy

January 14, 2016 By AMK

Reviews reveal common problem: Contract files lack documentation

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

August 14, 2015 By AMK

Postal Service purchase card program needs better oversight, new audit finds

A new U.S. Postal Service audit found inadequate oversight in regards to the use of expense purchase cards despite policies and procedures in place.

The USPS inspector general (IG) said in an Aug. 7, 2015 report that, of the 209 transactions – worth $72,333 – it reviewed, 133 were missing the required documentation. And, of those missing, 51 were made without proper approval.

Additionally, cardholders for 42 percent of the transactions and approving officials for 41 percent either did not take the required expense purchase card training or could not provide proof of completion, the IG said.

Keep reading this article at: http://www.fiercegovernment.com/story/postal-service-purchase-card-program-needs-better-oversight-new-audit-finds/2015-08-12

November 5, 2014 By AMK

DCMA releases review of Defense procurement functions

The Defense Contract Management Agency (DCMA) issued a summary of the results of its FY14 review of Defense Department (DoD) procurement functions. The purpose of DCMA’s annual reviews is to assess the effectiveness of the contracting function, including the identification of best practices and lessons learned.

Shortcomings identified in DCMA’s Program Management Review report include:

Insufficient documentation in contract files, contrary to instructions in FAR part 4.801.
Over-reliance on checklists and templates, reducing necessary analysis and substance required in particular circumstances.
Technical evaluations lacking critical analysis.
A propensity to accept proposed prices and an aversion to negotiation.
Lack of evidence that Contracting Officers are reviewing the actions and files of Contracting Officer’s Representatives during post-award contract administration.
Minimal documentation supporting contract modifications.
Misalignment of effective dates with periods of performance, funding dates, and signatures.

A copy of the DCMA’s report can be downloaded by clicking here.

October 20, 2010 By AMK

GAO: Documentation, communication key to management success

Agencies need management plans for successful programs, although the best plans risk failure if officials don’t document and communicate their work, the Government Accountability Office has found.

Federal regulations and guidance point to the importance of a strong management process. Without it, an agency can lose control of a would-be well-run operation, GAO said. And agencies won’t know if contractors are meeting expectations on their performance and products if officials don’t document all reviews and if they don’t tell the contractors.

For example, the Homeland Security Department defined important ways to manage and oversee that a contractor’s products and services adequate, but officials didn’t fully put the process into practice, GAO wrote in a report released Oct. 18 on about DHS’ Customs and Border Protection’s (CBP) Secure Border Initiative (SBInet).

Officials have been conducting technical reviews of the contractor’s work, and reviews check whether the company has met the agreed-to criteria before commencing and later concluding a critical design review, GAO said. DHS also trained officers who work closely with the contractor, including project managers and contracting officer’s technical representatives, on the acquisition process and rules.

However, because DHS didn’t put its management process fully into place, officials were limited in their ability to know whether the contractor met expectations on its performance and products, GAO wrote. As a result, DHS increased the chances that SBInet won’t function as intended and will take more time and resources than necessary to accomplish.

GAO wrote that CBP officials should have been documenting their good and bad reviews, both for products and services and technical designs. They also should have been talking with the contractor about the reviews so they could get on the same page about performance.

“Without documenting all its reviews and effectively communicating the review results to the contractor, the [officials have] increased the chances of accepting deliverables that do not meet requirements and having the contractor repeat work to correct deliverable problems,” GAO wrote.

GAO recommended that officials set appropriate criteria for starting and ending each technical review and have the criteria met before concluding a review. Officials should conduct thorough reviews and should not be constrained by late contractor deliverables and imposed milestones. Officials should document reviews and write to the contractor about why they accepted or rejected the product or service and should give explicit explanations for rejections, GAO said.

— by Matthew Weigelt – Oct. 20, 2010 – Federal Computer Week

The Defense Contract Management Agency (DCMA) reports that contract files contain insufficient documentation “across the board.”

A new U.S. Postal Service audit found inadequate oversight in regards to the use of expense purchase cards despite policies and procedures in place.

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