Blog Tags - File documentation

By far the biggest two findings for companies going through the CPSR process, inadequate source justifications and price analyses seem to plague even the most developed purchasing systems. The usual remediation steps - training and increased internal pre-award review - are no doubt effective, but it's my opinion that too few companies go to the source of many analysis issues: the forms used to document the evaluation.

Many consultants (and the companies that hire them) go forward with one clear and predominant message - over-documentation is better under-documentation. A fat file is better than a skinny file Flood them with enough paperwork and you might luck out and have the auditor throw up their hands in defeat!

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. 

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.

I'd like to discredit a common misconception regarding file documentation up front: Thick files DO NOT NECESSARILY EQUAL compliant files. 

An antiquated approach to dealing with auditors goes something like this: Inundate them with reams of documentation. Put them in a cramped room with no AC in the summer. Sweat them out and they'll leave before they can find anything.

Have you ever asked yourself - are my files pretty?

That's a serious question! There seems to be an industry-wide perception that "ugly equals serious" - the less aesthetically attractive and paper-thick a file is, the more serious a reviewer will take. Nothing could be farther from the truth. In fact, the uglier and more convoluted a file structure is, the more likely it is that your system will suffer for it. 

First, the higher the dollar value the more objective evidence DCMA will expect in support of award. 

The first answer addresses the last misassumption that files are "filed away" once the procurement is complete. That is, of course, silly. I make sure I leave requisitioner with two points.  

First, any file with a total anticipated ceiling exceeding $500,000.00 WILL get reviewed by DCMA, and DCMA will read EVERY piece of paper in that file. 

The farther a procurement strays from the Three Big C's of government procurements - Competition, Commercial Items and Constrictive Contract Types - the more documentation is required for a compliant file, the more public laws apply and the more opportunity for the file to create findings.