Att 0009 Purchasing and Invoicing Guide.pdf

ENHANCED ACQUISITION GLOBAL LOGISTICS ENTERPRISE

(EAGLE) GUIDE FOR GOVERNMENT APPROVAL &

OVERSIGHT OF CONTRACTOR PURCHASING & INVOICING

This guide details the process that the United States Government (USG) will use to conduct and oversee contractor purchasing and invoicing for each EAGLE Task Order. Each step in the process will be described in detail along with the responsibilities of each individual position. It is the intent of the Government that the process will be sufficient for detailed cost accounting and approval without negatively impacting the contractor’s ability to provide Maintenance, Supply, and Transportation services at each location. If the process is found to negatively impact operations it will be re-evaluated by the USG and updated appropriately to achieve the desired effect.

The guide is comprised of seven sections:

(1) Decisions made defining the course of action detailed in this guide

(2) Roles and responsibilities in the purchasing & invoicing process

(3) Flow diagrams for both the purchasing and invoicing processes

(4) Resources

(5) Samples

(6) Appendix

(1) DECISIONS MADE DEFINING THE COURSE OF ACTION DETAILED IN THIS GUIDE

(i) As of the date of this guide, for the purpose of temporary duty (TDY) requests, purchasing supplies/expendable goods and equipment/durable goods, the Contractor shall obtain written validation from the Contracting Officer’s Representative (COR) and approval from the Procuring Contracting Officer (PCO) for those purchases that fall within the Other Direct Cost (ODC) surrogate CLIN defined in the contract. Justification letters are required for each request for documentation purposes and will be retained for referencing during invoice review. Any purchase made without gaining the proper approvals is at the contractor’s own risk. Separate invoices for Labor and ODC CLINs are to be submitted to avoid delaying the approval of Labor invoices.

Every contractor purchase request (PR), at or above the micro-purchase threshold, must be validated (as defined in this guide) by the COR, concurred on by the ACO, and approved (as defined in this guide) by the PCO. For PRs below the micro-purchase threshold the COR is the validation and approval authority; however, should be reviewed with the delegated Administrative Contracting Officer (ACO) to validate authorized purchases. TDY requests, regardless of the dollar amount, must be validated by the COR and approved by the PCO.

(ii) The purchase approval and invoice review process will be managed via e-mail. The pervasiveness of e-mail connectivity should allow the Contractor, COR, ACO and PCO to communicate freely and effectively.

(iii) All interim cost invoices will be entered into the Wide Area Work Flow (WAWF) system as a “Cost Voucher” and approved by the Defense Contract Audit Agency (DCAA) after email concurrence from the PCO and COR. The Final cost invoice (i.e. last one of the performance period) will be entered into WAWF as a “Cost Voucher” and processed and paid by DFAS via WAWF. (Appendix 1)

(iv) All fixed price invoices (e.g . Transition-In and Program Management Office (PMO) CLINs) will be entered into WAWF as “2-in-1 Services Only” and approved by the PCO. (Appendix 1)

(2) ROLES AND RESPONSIBILITIES IN THE PURCHASING & INVOICING PROCESS

(a) Contractor

Role: Single Logistics Provider for Maintenance, Supply and Transportation tasks at each site.

Purchase Process Responsibilities: The contractor will take direct action during the purchase process.

Upon recognizing the need for a purchase, the contractor will submit a complete PR, including a minimum of three competitive quotes (or single source vendor justification) for needed supplies/equipment/service for all purchases exceeding the micro purchase threshold (as defined in RFO FAR 2.101), to the on-site COR (if the on-site COR is not available the contractor will provide the PR directly to the PCO). Purchases that are under the micro purchase threshold may be awarded without soliciting competitive quotations so long as the PCO or appointed individual considers the price to be reasonable, as noted in RFO FAR 12.402(b). NOTE: RFO FAR 2.101 assigns dollar values for the micro-purchase threshold differently for supplies and services. The PR should clearly state the justification for each item/service requested. The COR will disapprove (with rationale) or validate (does not give the contractor direction) the item/service for purchase. If validated, the PR will be sent from the COR and/or ACO to the PCO for an approval determination. For purchases above the micro-purchase threshold, the PCO will review the validated PR and if acceptable will sign the document clearly annotating “Approved”. A PR signed “Approved” by the PCO is the only document that gives government approval to the contractor to make the purchase. Once the signed/approved documentation is received from the PCO the contractor is authorized to make the purchase.

Upon receipt of the purchased item, the contractor will coordinate with the on-site COR and/or ACO to ensure that all items that were approved on the PR/justification letter are documented appropriately in the contractor’s property book system.

Invoice Process Responsibilities: The contractor will take direct action during the invoice process. Specifically, the contractor will submit an invoice for all incurred costs within 45 calendar days of incurring the cost to the COR and/or ACO and the PCO for concurrence prior to submission into the WAWF system. To ensure strict compliance with RFO FAR 52.216-7, all invoiced costs must represent actual payments made, while any costs that are incurred but not yet paid must be tracked and reported separately via the monthly CDRL CD-02.

If the invoice contains items purchased through the government purchase process, the invoice will reference the purchase request or purchase order number(s) associated with the purchased line item.

The contractor shall ensure each item purchased has been received and recorded in the property book.

The contractor shall submit their invoice package for COR review and ACO concurrences prior to submitting for PCO review and approval. Once the invoice is submitted to the PCO, it will be reviewed, and concurrence or nonconcurrence by the PCO shall be obtained prior to submission into WAWF and DCAA before DFAS payment. The contractor will not submit any invoices for payment that have not been approved by the PCO.

Upon receiving written concurrence from the PCO, the contractor will generate in WAWF either a “Cost Voucher” for cost-type invoices (e.g, labor/fee and ODC CLINs) or a “2-in-1 Services Only” for firm-fixed-price type invoices (e.g, Transition–In and PMO CLINs). Finally, the contractor will attach and upload the email concurrences from both the PCO and COR, along with the DCAA-required backup data, to support cost invoices. Indirect rates will be trued up after a final Incurred Cost Audit (ICA) is completed or a Low- Risk Memo (LRM) is provided.

Note: All but the last cost type invoice will be entered as an “Interim Cost Voucher” and the last cost invoice of the performance period will be entered as a “Final Cost Voucher.”

(b) Contracting Officer’s Representative (COR)

Role: On-site government representative observing the day-to-day operations performed by the contractor. Validates contractor requests for purchase and confirms received items are accurately accounted for in the Contractor’s records.

Purchase Process Responsibilities: The COR will take direct action during the purchase process. The COR will be the first person the contractor approaches with a PR, including estimated prices (if the COR is unavailable then the contractor is to go directly to the ACO). The COR shall submit each PR to ACO for concurrence prior to validating. The COR will review the PR for appropriateness and, if the request is deemed inappropriate, will return the package to the contractor with constructive comments. If the request is deemed prudent, the COR will validate* the purchase request (*validation does not financially obligate the government, nor does it give the contractor direction to purchase) by signing the PR (written or electronic signature) and clearly stating “Validated”. In situations where the PR is above the COR’s approval threshold, the COR will submit the validated PR, along with three competitive quotes, to the Contracting Office for the PCO's review and approval.

Purchase Type Validation Authority Approval Authority Purchases at or above the micro-purchase threshold COR/ACO PCO Purchases under the mirco-purchase threshold COR/ACO COR

For filing purposes, the subject of the e-mail will be, “EAGLE TASK ORDER (site name) — Validated Contractor Purchase Request # XXXX”. If the PR is approved by the PCO, then the COR will receive (cc e-mail) a copy of the approved PR for his/her records.

The COR is also responsible for confirming that purchased items are properly annotated in the Contractor’s property system when the purchased items arrive on site. The COR will ensure the item matches what was approved on the PR and will ensure that the item is properly documented in the contractor’s property book system. Upon completion, the COR will send an e-mail to the PCO documenting the successful receipt and annotation of property by the Contractor. For filing purposes, the subject of the e-mail will be, “EAGLE TASK ORDER (site name) —PR# XXXX confirmed in Contractor property system”.

Invoice Process Responsibilities: The COR takes direct action during the invoice approval process. The COR, in coordination with the PCO, provides confirmation of receipt of services and supplies and annotation of property by the Contractor for items included in the invoice. The COR is allowed 5 business days to review and concur on the invoice. The on-site COR shall provide its concurrence to the Contractor’s site manager. The Contractor site manager will provide the COR-validated invoice to the PCO for review. After 6 business days, invoice is deemed to be authorized by the COR for payment if the COR has not taken a position on the invoice. In this instance, the Contractor will submit invoice to the PCO for approval without the CORs concurrence stating the COR review time had expired. Should corrections be necessary, these will be made on the next invoice for those items found by either COR or

PCO.

(c) Administrative Contracting Officer (ACO)

Role: On-site government representative observing the day-to-day operations performed by the contractor. Validates contractor requests for purchase and confirms received items are accurately accounted for in the Contractor’s records.

Purchase Process Responsibilities: The ACO will take direct action during the purchase process. The COR will be the first person the contractor approaches with a PR, including estimated prices. If the COR is unavailable, then the contractor is to go directly to the ACO. The COR shall submit each PR to ACO for concurrence prior to validating. The ACO will review the PR for appropriateness and, if the request is deemed inappropriate, will return the package to the contractor with constructive comments. If the request is deemed prudent, the COR and/or ACO will validate* the purchase request (*validation does not financially obligate the government, nor does it give the contractor direction to purchase) by signing the PR (written or electronic signature) and clearly stating “Validated”. In situations where the PR is above the COR and/or ACO’s approval threshold, the COR and/or ACO will submit the validated PR, along with three competitive quotes (or single source vendor justification), to the Contracting Office for the PCO's review and approval.

Purchase Type Validation Authority Approval Authority Purchases at or above the micro-purchase threshold COR/ACO PCO Purchases under the micro-purchase threshold COR/ACO COR

For filing purposes, the subject of the e-mail will be, “EAGLE TASK ORDER (site name) — Validated Contractor Purchase Request # XXXX”. If the PR is approved by the PCO, then the COR and ACO will receive (cc e- mail) a copy of the approved PR for his/her records.

The COR, along with the ACO, is also responsible for confirming that purchased items are properly annotated in the Contractor’s property system when the purchased items arrive on site. The COR and/or ACO will ensure the item matches what was approved on the PR and will ensure that the item is properly documented in the contractor’s property book system. Upon completion, the COR and/or ACO will send an e-mail to the PCO documenting the successful receipt and annotation of property by the Contractor. For filing purposes, the subject of the e-mail will be, “EAGLE TASK ORDER (site name ) — PR# XXXX confirmed in Contractor property system”.

Invoice Process Responsibilities: The COR and/or ACO take direct action during the invoice approval process. The COR and/or ACO, in coordination with the PCO, provides confirmation of receipt of services and supplies and annotation of property by the Contractor for items included in the invoice. The COR and/or ACO are allowed 5 business days to review and concur on the invoice. The on-site COR shall provide its concurrence to the Contractor’s site manager. The Contractor site manager will provide the COR and/or ACO-validated invoice to the PCO for review. After 6 business days, invoice is deemed to be authorized by the COR and/or ACO for payment if the COR and/or ACO has not taken a position on the invoice. In this instance, the Contractor will submit invoice to the PCO for approval without the CORs concurrence stating the COR review time had expired. Should corrections be necessary, these will be made on the next invoice for those items found by either the COR and/or ACO or PCO.

(d) Procurement Contracting Officer (PCO)

Role: Warranted individual capable of financially obligating the government; ensures the Contractor is abiding by the terms of the contract

Purchase Process Responsibilities: The PCO will take direct action during the purchase process. The PCO will receive a PR from the Contractor including a minimum of three competitive quotes (or single source vendor justification) that was reviewed and validated by the COR and concurred on by the ACO. The PCO will review the PR for appropriateness regarding price reasonableness and assuring the contractor follows the proper purchasing process. If acceptable, the PCO will sign the contractor’s PR clearly stating “Approved”. The PCO will provide a signed copy (via e-mail) of the PR to the contractor as well as the COR for their records. If the PR is deemed unacceptable, the PCO returns the package to the contractor with constructive comments and the formal disapproval. The PCO files the PR as official record of the government’s approval to the contractor to make the purchase.

Invoice Process Responsibilities: The PCO takes direct action during the invoice process. The PCO will receive the contractor’s invoice from the contractor via email prior to entering into WAWF. If material purchases are included on the invoice the PCO will conduct a sampling cross-check of no less than 40% of the total costs of the invoiced items with the PRs. Once the sampling of line items on the invoice are validated and the PCO receives the COR validation and ACO concurrence of the invoice, the PCO will concur on the invoice and provide concurrence to the contractor for input into WAWF. The PCO has 3 business days to provide concurrence after receipt of the COR validation and ACO concurrence of the invoice.

If a firm fixed price CLIN is being invoiced (2-in-1 Service Only) the PCO will enter into WAWF and approve the contractor’s invoice for payment. If a cost CLIN is being invoiced (Cost Voucher) the PCO is not required to take any action in WAWF as DCAA reviews and ultimately approves/disapproves in WAWF.

(e) Defense Contract Audit Agency (DCAA)

Role: Independent auditing of contractor invoices.

Purchase Process Responsibilities: DCAA does not take direct action during the purchase process.

Invoice Process Responsibilities: DCAA takes direct action during the cost invoice process. DCAA performs a review of cost invoices (Cost Vouchers) prior to approval to DFAS authorizing payment.

If the contractor’s billing system is not approved for direct billing then DCAA will have the responsibility of reviewing all invoices prior to payment of the invoice by DFAS. If direct billing is approved then a random sample will be reviewed in accordance with DCAA established parameters.

Purpose: The primary purpose is to review the voucher to provide reasonable assurance that the amounts claimed are not in excess of that which is properly due the contractor in accordance with the terms of the contract prior to approval of provisional payment. Additionally, the review is to ensure that contract overpayments are identified promptly and that any amounts due the government are refunded timely or properly offset. DCAA shall not process any invoice in WAWF if it does not have the PCO’s email concurrence. The PCO’s email concurrence serves as confirmation that the COR and PCO have completed their reviews prior to submission in WAWF.

(3) FLOW DIAGRAMS FOR BOTH THE PURCHASING AND INVOICING PROCESSES

(a) Purchasing Flow Diagram

1. Contractor identifies need for purchase PR Package Submittal:

1) Documents need on contractor generated numbered purchase request (PR)

2) Provides 3 quotes (or single source vendor justification) for the product to allow for the best value determination

Send via e-mail or hand delivers PR to COR (or ACO if COR unavailable)

2. COR receives contractor PR package (or ACO if COR unavailable) Reviews package for appropriateness/reasonableness/best value Submit each PR to ACO for concurrence prior to validating If deemed acceptable, validates with signature clearly indicating “validated” and e-mails validated package to PCO E-mail subject line: “EAGLE Task Order (site name) -Validated Contractor Purchase Request” If deemed unacceptable, returns package to contractor with constructive comments

(b) Invoice Flow Diagram

1. Contractor submits electronic invoice to the COR/ACO & the PCO for concurrence prior to submission in Wide Area Work Flow

(WAWF)

The Contractor will provide the COR and ACO concurrences with the invoice package to the PCO for review and approval.

The contractor is to submit all incurred cost within 45 calendar days of incurring the cost.

If the invoice contains items purchased through the Government Purchase process, the invoice will reference the Purchase Request (PR) or Purchase Order (PO) number(s) associated with the purchased line item.

2. PCO reviews contractor submitted invoice package with COR validations and ACO concurrence If material purchases are included in the invoice, the PCO will conduct a sampling cross-check of no less than 40% of the total costs of the invoiced items against the PRs to validate.

Once validated and COR and ACO validation received, the PCO will concur on the invoice and provide it to the Contractor with written concurrence to load the invoice into WAWF.

The PCO has 3 business days to review and either Approve or Disapprove the invoice from time of receipt. The COR and ACO have 6 business days to validate or not the invoice from time of receipt.

If rejected, the PCO will return invoice package to the Contractor with constructive comment and courtesy copy the COR

5. Contractor purchases the approved item Documents purchase in company records, once received then notify the COR of arrival (References PR number)

Send via e-mail or hand delivers PR to COR (or ACO if COR unavailable)

5. PCO receives PR number Retain in PCO files for invoice matching

6. COR and ACO acknowledge Contractor receipt of the purchased item at the request of PCO Confirms received product matches that approved on the numbered PR/justification letter Confirms that the Contractor enters the property into its property book in accordance with FAR 52.245-1 Sends e-mail to PCO with subject line “EAGLE TASK ORDER (site name) - PR# xx Confirmed in Contractor Property

7. PCO retains e-mail record

3. Contractor inputs consolidated invoice in Wide Area Work Flow (WAWF) per DFARS 252.232.7003 for government approval

4. DCAA reviews the signed invoice, performs a pre-payment verification of billing in accordance with DCAA procedures If the invoice is compliant, DCAA approves the invoice for payment.

If rejected, DCAA will return invoice package to the contractor with constructive comment If firm fixed price, PCO performs acceptance in lieu of DCAA (Appendix 1)

4. PCO receives the PR package, only above micro-threshold Makes an assessment based on appropriateness/reasonableness/best value If deemed acceptable, the PCO signs the PR clearly indicating “approved” and provides the package to the Contractor via e-mail PCO courtesy copies the COR and ACO with the approved PR for their records If deemed unacceptable, the PCO returns the package to the Contractor with constructive comments

3. ACO receives PR package (COR unavailable) Absents of COR, complete COR responsibilities above When COR is available ACO will:

o Reviews package for appropriateness/reasonableness/best value o If deemed acceptable, concur with clearly indicating “concurrence” and e-mails concurrence package to COR

If deemed unacceptable, returns package to contractor with constructive comments

(4) Resources

Assistance with WAWF invoicing can be found at https://cac.piee.eb.mil/xhtml/auth/web/homepage/vendorCustomerSupport.xhtml

Resources include

a. Account

b. Access and Admin support:

https://cac.piee.eb.mil/xhtml/unauth/lookup/gamLookup.xhtml

c. Payment and invoicing support

d. Web Based Training: https://pieetraining.eb.mil/wbt/

(5) SAMPLES

The following sample Documents are found on the proceeding pages:

a. Blank Purchase Request Document

6. COR and ACO reviews the item purchased upon receipt by the Contractor Ensures that it matched what is listed on the PR and records confirmation in the Contractor’s Property Book

Requisition No. Requisition Date:

Deliver To:

Name

Phone #

Email

Site

Department

I tem Qty U/M Est. Unit Price Total Charge Code

Justification:

Date Date

Date Date

Date Date

Date

Logistics Manager Approval (5)Site Manager Approval(2)

Requested By:

Priority Required Delivery Date

Complete Description (Reference Attachments if required)

Email

Site

Department

ACO Approval(7)

DPM Aprroval (6)

TOTAL:

COR Validation(4)

Budget & Finance Approval(3)

PROGRAM PURCHASE REQUISITION

Request By:

Name

Phone #

(6) APPENDIX