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What’s in a Contract File? Organization, Maintenance and Retention. Breakout Session #210 Trish Downing, Contracts Manager Monster Government Solutions April 25, 2006 2:40 pm. What Should Be Retained. Proposal Contract Subcontracts Deliverables Reports Invoices Correspondence
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What’s in a Contract File? Organization, Maintenance and Retention Breakout Session #210 Trish Downing, Contracts Manager Monster Government Solutions April 25, 2006 2:40 pm
What Should Be Retained • Proposal • Contract • Subcontracts • Deliverables • Reports • Invoices • Correspondence • Closeout
Proposal • RFP/RFQ/Solicitation • All submitted responses • All RFP work papers, including pricing docs • All subcontractor related documents • All correspondence with selecting officials
Contract • Contract Award documents • Recommended additions: • Full text copies of all FAR clauses incorporated by reference • Full copies of any other documents incorporated into the contract by reference • SOW • Modifications • Contract Brief • Correspondence and documentation of verbal communications
Subcontracts • All source selection – pre-award documents such as: • Market research • Documents identifying how potential subs were identified • Documents identifying how small business were provided equitable opportunities to be included in the pool of potential subs • Teaming Agreements, NDAs, etc. • RFP/RFQs and SOWs issued to potential subs • Proposal responses received • Evaluation criteria
Subcontracts • All post-award documents such as: • Negotiation memorandums • Final subcontract award document • Modifications • Final Pricing • Subcontractor reports • Invoices • Correspondence
Deliverables • Comprehensive list with due dates • Items may include: • Periodic reports • Shipping and receiving documents • Inspection and acceptance documents • Government property
Reports • Periodic Project Reports • Project Plans • Small Business Subcontracting Reports • Property Reports • Any other reports required by the contract
Invoices • Copy of Each Invoice • All Backup to support invoice to include • Project summary reports • Labor distributions • Receipts • Vendor Invoices
Correspondence • Letters • Emails • Faxes • Call logs
Closeout • Collect all final documents to include: • Final Invoice • Final Negotiated Indirect Rate Agreement • All closeout documents, such as release of claims, patents, transfer of title, etc. • Organize files for retention
FAR Part 4 – Administrative Matters • Subpart 4.7-Contractor Records Retention • This is written specifically for CONTRACTORS • The scope reads: “This subpart provides policies and procedures for retention of records by contractors to meet the records review requirements of the Government. In this subpart, the terms “contracts” and “contractors” include “subcontracts” and “subcontractors.””
FAR 4.702 Contractor Retention Records-Applicability • FAR 4.7 applies to records generated under contracts containing one of the following clauses: • FAR 52.214-26 Audit and Records-Sealed Bidding or • FAR 52.215-2 Audit and Records-Negotiation
FAR 4.7 Contractor Records Retention • FAR 4.703 Policy • Describes types of records to have available for audit and how they may be stored and/or provided • FAR 4.704 Calculation of Retention Periods • Describes how the retention periods are calculated in FAR 4.705 • Calculated from end of the contractor’s fiscal year • Contractor should cut off the records and retain them in annual blocks.
FAR 4.705 Specific Retention Periods • FAR 4.705-1 Financial and cost accounting records • Accounts receivable invoices, adjustments to the accounts, invoice registers, carrier freight bills, shipping orders, and other documents which detail the material or services billed on the related invoices: Retain 4 Years
FAR 4.705 Specific Retention Periods • FAR 4.705-1 Financial and cost accounting records (b) Material, work order, or service order files, consisting of purchase requisitions or purchase orders for material or service or orders for transfer of material or supplies: Retain 4 years
FAR 4.705 Specific Retention Periods • FAR 4.705-1 Financial and cost accounting records (c) Cash advance recapitulations, prepared as posting entries to accounts receivable ledgers for amounts of expense vouchers prepared for employees travel and related expenses: Retain 4 years
FAR 4.705 Specific Retention Periods • FAR 4.705-1 Financial and cost accounting records (d) Paid, canceled, and voided checks, other than those issued for the payment of salary and wages: Retain 4 years
FAR 4.705 Specific Retention Periods • FAR 4.705-1 Financial and cost accounting records (e) Accounts payable records to support disbursement of funds for materials, equipment, supplies and services containing original copies of all related documents: Retain 4 years
FAR 4.705 Specific Retention Periods • FAR 4.705-1 Financial and cost accounting records (f) Labor cost distribution cards or equivalent documents: Retain 2 years (g) Petty cash records showing full descriptions of expenditures, to whom paid, and all supporting documents: Retain 2 years
FAR 4.705 Specific Retention Periods • FAR 4.705-2 Pay administration records (a) Payroll sheets, registers, or their equivalent, of salaries and wages paid to individual employees for each payroll period, change slips; and tax withholding statement records: Retain 4 years
FAR 4.705 Specific Retention Periods • FAR 4.705-2 Pay administration records (b) Clock cards or other time and attendance cards: Retain 2 years (c) Paid checks, receipts for wages paid in cash, or other evidence of payments for services rendered by employees: Retain 2 years
FAR 4.705 Specific Retention Periods • FAR 4.705-3 Acquisition and supply records (a) Store requisitions for materials supplies equipment and services: Retain 2 years (b) Work orders for maintenance and other services: Retain 4 years
FAR 4.705 Specific Retention Periods • FAR 4.705-3 Acquisition and supply records (c) Equipment records, consisting of equipment usage and status reports and equipment repair orders: Retain 4 years (d) Expendable property records, reflecting accountability for the receipt and use of material in the performance of a contract: Retain 4 years
FAR 4.705 Specific Retention Periods • FAR 4.705-3 Acquisition and supply records (e) Receiving and inspection report records, consisting of reports reflecting receipt and inspection of supplies, equipment and materials: Retain 4 years
FAR 4.705 Specific Retention Periods • FAR 4.705-3 Acquisition and supply records (f) Purchase order files for supplies, equipment material, or services used in the performance of a contract; supporting documentation and backup files including, but not limited to, invoices and memoranda; e.g., memoranda of negotiations showing the principal elements of subcontract price negotiations (see FAR 52.244-2): Retain 4 years
FAR 4.705 Specific Retention Periods • FAR 4.705-3 Acquisition and supply records (g) Production records of quality control reliability, and inspection: Retain 4 years
Additional Clauses to Read • FAR 4.8 Government Contract Files • FAR 44.3 Contractors Purchasing system Review • FAR 45 Government Property
Final Note Organize and identify all files related to a particular contract in such a manner that you can easily combine and store them at the end of the contract. Keep a comprehensive list of the documents stored and the date the contract was finally closed by the government for ease of disposal when the time comes.
Questions? • For more information please contact me, Trish Downing at 703-269-4982 or at trish.downing@monster.com • Please visit the NCMA Potomac Chapter website for additional contract management information: http://intranet.ncmahq.org/i-270hightechcorridor/default.aspx