February 17, 2014

Going Paperless

Many contractors use paper files because of a singular concern: DCMA "walking around" in their file rooms during a CPSR, even though e-files make sense from policy and performance perspective. Not only are contractors required to maintain a policy on Electronic Procurement Methods which state contractors will use electronic means whenever practicable to eliminate waste and increase efficiency, but a contractor trying to document compliance with DFARS 252.244-7001(c)(18)(requiring an internal review program) with paper files maintained in remote offices will be frustrated during and after their CPSR trying to provide evidence of compliance with paper files. I’d like to talk about going paperless and provide some considerations to incorporate into your paperless process.

File formats: Files can be stored as a single merged document in checklist order or as documents in separate folders set as file tabs. Either is acceptable, however I would not suggest keeping merged subcontract files. Consider mixing these two methods. Files for commercial item POs are much "slimmer" which makes sense as a merged file. For noncommercial subcontracts, with so many potential "moving parts," separating out documentation to facilitate efficient reviews is a good approach. 

DCMA in your e-file room: Many contractors are concerned with DCMA "touring" their e-file room without oversight. Let me first say that you are never "in control" when the government is onsite. DCMA can tour your file room anytime they want, paper or paperless. Keep in mind, though, that DCMA TAKES THEIR TIME reviewing files. I've seen a team of 3 take 8 days to review 79 files. If they get too far "off book" and take long strolls outside the data call request, they still have file quotas to maintain (DCMA is much stricter about following the file review algorithm). Which is why DCMA doesn't usually take long walks through file rooms anymore!

DCMA will review any electronic systems used for purchasing system compliance to ensure the existence of standardized mechanisms to track activity within the system. This is not a license to perform a "fishing expedition." And they can always go fishing - and paper file fishing can be scary. 

What if DCMA asks for 20 more paper files from a remote location during a CPSR? How can you get them in time? Are you comfortable handing them over when they arrive? Even if you maintain e-files, you will still provide DCMA with requested files set aside for review per their request (thumb drive, CD-ROM, etc. is usually used). They don’t typically pull files from your file room, especially if you have a chronological numbering system which mixes direct and indirect orders.

Keep the e-files organized and neat. No extra documents. Centralize files in one directory and limit DCMA access to that directory while onsite. Be ready for an additional request for files during a CPSR. It’s happened in 3 of the last 4 CPSRs for which I’ve provided support. Additional remote files may be requested during your review; paper files can provide a false sense of security. Do you think DCMA won’t ask for more files from remote locations because it’s hard for you to get those files and you’re not sure if they’re compliant? Or are those affirmative reasons for them to ask for those files during a CPSR to perform a pop quiz on system adequacy?

Emails: Cut and Convert. Cut emails out of files that do not meet a specific documentary requirement. Then sever/cut any discussions that are not pertinent to the requirement. You are not required to provide the entire string!

Convert the email to .pdf. Don't assume DCMA brings Outlook on their laptops. If they can't read the email, they won't count it during their review.