February 17, 2014

The Illusion of Weight

Many contractors hold an assumption about manuals and files dear and true - the bigger the better! The reasoning for this assumption is that weight is impressive to reviewers. In other words, the more time spent and trees killed to make a point or build a file, the more your company cares about the underlying requirements. 

This weight, the theory goes, will surely impress DCMA. Or, better yet, they will be overwhelmed by the sheer volume of the undertaking, throw the flag and pass the system out of simple respect. 

I would like to discount this theory and provide some potential solutions for leaning out your documentation. 

First to discount - (1) DCMA will definitely read EVERYTHING you put in front of them. They will call in extra hands to help with the review. If DCMA is not available with surge support, DCAA will DEFINITELY volunteer to help out with file review. Large files can actually attract additional scrutiny from outside agencies quickly. (2) The lettuce used to fluff up files - emails, NDAs, random certs and Teaming Agreements mostly - are death traps of potential findings for reviewers. In particular, unreviewed email strings and TAs executed prior to requisition should never be included in files. (3) When extensive documentation is unnecessary, presenting a large file is suspicious. When I am presented with a 200 page file for a commercial item acquisition under the SAP, I am immediately suspicious of the documentation as a reviewer. Why did it take so long to explain a simple transaction? What makes the buyer so nervous that they spent THIS much time on the file? 

Manuals track along the same trajectory. Inserting unnecessary policies distracts and confuses reviewers. Including forms and templates in your manual means that (a) if the form is not present in the file for the intended purpose, a finding results; and (b) major changes to that form post-CPSR may have to be approved by DCMA prior to implementation. Over-engineering a process through lengthy policy discussion could handcuff procurement professionals (and result in unneeded findings if the process is not followed during a procurement). 

For files, keep in mind that simple transactions (the ones where you do what the FAR wants - procuring commercial items on a competitive FFP basis from small businesses) your file SHOULD be slim and lean. For bigger more complex procurements, work on condensing documentation to reduce reviewer "hunt time." Provide summary matrices in price analyses; condense reference material for source justifications; explain issues in the Award Summary rather than wait for a question during a CPSR. The faster a reviewer can make a determination about your system adequacy, the better. 

For manuals, make sure your policies are not needlessly complex or intricate. Keep it relatively high level with explanations of the policy and FAR DFARS references; applicability and thresholds; procedure; exceptions; list of resulting documentation. This is the "what" of the system. Move the "how" (workflows; particular forms and templates; process maps, etc.) to work instructions. Those work instructions do not have to be provided to DCMA during a CPSR, which means they stay out of the audit universe and can be manipulated, updated and revised at any time (in simple accordance with any other internal certifications your company maintains - ISO, etc.). Finally, make sure your policy doesn't make promises your system can't keep. In particular, look over your SSJ, PA and TINA policies. Make sure you're not cheating yourself out of competition or easy documentation outs, and don't make yourself perform cost analysis!