February 17, 2014
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.
Here's how CPSRs work now: Put DCMA in a cramped room with no AC? They'll demand to be moved. The room will also need a printer, fax, internet access, a phone that dials out and a lock. Inundate them with paperwork? Okay - CPSR is extended and more analysts may be called in to pick up the slack.
Fat files don't scare auditors - they anger them! Some of my roughest reviews came out of ridiculously thick files filled with reams of email communication. Is that because I was angry?
Actually no. They were rough because email strings are treasure troves of noncompliance. Real life example:
I worked for a client as part of a consulting company a few years ago. The Friday before the review commenced we asked the client to have all $500K+ files in the DCMA audit area ready for review. We'd been working for months on remediative efforts - time to tab, stack and go!
When the files showed up 9am Monday, several of the ID/IQ files got mysteriously ... bigger. Like, an extra hundred pages a piece. No time for questions, in-brief started. Deep breath and let's dive in.
As the questions started coming in on those "fat" files we found out what happened - the SCA, in a bit of a panic, decided to print out ALL of her emails from the proposal evaluation stage (which no one had seen during pre-CPSER review) and shoved them into the file Friday night. She was worried that her files weren't big enough to impress the auditors. The problem - the files documented a competitive ID/IQ price analysis. However the emails that were a late add included conversations between BD and subs where target rates were provided to the subs prior to their price proposal submissions.
All of a sudden, the first 10 files DCMA reviewed (all part of the same ID/IQ prime) were deemed noncompetitive. 10 TINA violations before lunch on the first day.
What's to learn from that story?
1. Emails are dangerous. Emails should ONLY be included in a file when they fulfill a documentary requirement. DPAS acceptance; information from a sub regarding commerciality of a proposed item; approval or time stamp for a time-sensitive document, etc. Extraneous parts of the string should be cut.
2. Don't hide things during the remediation process! Mistakes happen. They get exponentially worse when the mistakes are a surprise to the contractor during a review. You can get leniency for mistakes with disclosure and proposed corrective action, but it can be disaster if DCMA finds something you're trying to hide.
|accounting system adequacy||ACO|
|advance notice and consent||anc|
|appproved configuration||audit results|
|award summary||bad findings|
|best practice||best value|
|blanket purchase agreement||BPA|
|business system rule||CAS|
|Case study||Certificate of Current Cost or Pricing|
|change management||Change Order|
|commercial item||commercial items|
|commercial price lists||Commercial Services|
|comparative range rate reduction||competition|
|competitive price analysis||Compliance|
|Consulting Agreements||contract types|
|Cost Accounting Standards||Cost Analysis|
|CPSR Data Calls||CPSR Questions|
|customer direction||data call|
|deference to preference||DFARS 252.242.7005|
|DFARS 252.244-7001||DFARS 252.244-7001(c)(18)|
|fail a cpsr||FAR 15.403-1(c)(1)(iii)|
|FAR 16.104||FAR 2.101|
|FAR 52.210-1||FAR 52.211-15|
|FAR 52.232-7||FAR 6.3|
|FAR Part||FAR Part 12|
|File compliance||File documentation|
|file review||financial responsibility|
|findings||first time CPSR|
|GSA schedule||gsa schedules|
|inconsistancy||Independent contractor estimate|
|internal audit||internal audits|
|INTERNAL PROCESS||internal review|
|internal review process||invoices|
|large business||Lead Time|
|market research||memos to file|
|multiple file formats||no bid|
|noncompetitive price analysis||noncompetitive price anaylsis|
|objective evidence||olympic scoring|
|one source available||operations|
|ORCA||other than certified cost or pricing data|
|Other than FFP||other than firm fixed|
|other than firm fixed price||oversight|
|parametric pricing||peer review|
|pre-award subcontract||price analysis|
|price analysis narrative||process|
|process implementation||process improvement|
|Procurement File||procurement policies|
|procurement summary||proprietary rights|
|public law||published price list|
|published price lists||purchase order inquery|
|purchase requisition||purchasing manual|
|Representations and Certifications||Reps and Certs|
|sam FAR part 12||Sam.gov|
|significant funding||single source|
|single source justification||sole source|
|sole source justification||source justification|
|source justifications||Source Selection|
|task order||teaming agreement|
|technical evaluations||technical trade-off|
|theory of documentation relativity||TINA|
|trade off||unconditional purchasing system|
|vendor rating system||withhold|