Attachment 0009 - Fort Riley Purchasing Invoicing Guide 07OCT2020.pdf

ENHANCED ACQUISITION GLOBAL LOGISTICS ENTERPRISE

(EAGLE) FORT Riley TASK ORDER (W52P1J‐14‐R‐0154)

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 subject EAGLE Task Order for Fort Riley, KS. 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 Fort Riley, KS. 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 six (6) 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) Immediate and enduring actions required

(5) Summary

(6) Samples

(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 COR and approval from the PCO for those purchases that fall within the Other Direct Cost 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.

Every contractor purchase request (PR), regardless of dollar amount, must be validated (as defined in this guide) by the Contracting Officer’s Representative (COR) and approved (as defined in this guide) by the Procuring Contracting Officer (PCO).

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

(iii) All cost invoices will be approved by the Defense Contract Audit Agency (DCAA) after concurrence with the PCO and COR. At this time, due to the importance of cost oversight on this effort, it is the PCO’s desire that the contractor not be placed on direct billing (contractor invoices straight to the Defense Finance Accounting Services (DFAS)). All fixed price invoices will be approved by the PCO after concurrence of the COR.

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

(a) Contractor

Role: Single Logistics Provider for Maintenance, Supply and Transportation tasks at Fort Riley, KS.

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 for needed supplies/equipment/service, to the on‐site COR (if the on‐site COR is not available the contractor will provide the PR directly to the PCO). The PR should clearly state the justification for each item/service requested. The COR will disapprove of (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 to the PCO for an approval determination. 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 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. The contractor will produce an invoice on a regular basis for submission to the COR and the PCO for concurrence prior to submission into the Wide Area Work Flow (WAWF) system. 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 assure that the COR has annotated that each item purchased has been received and recorded in the property book. Contractor shall provide COR concurrences with its invoice package to the PCO for review/approval. Once the invoice is submitted to the PCO, it will be reviewed and concurrence/nonconcurrence by the PCO shall be obtained prior to submission into WAWF and DCAA before DFAS payment. If the contractor’s billing system is not approved for direct billing then DCAA will have the responsibility of review prior to payment of the invoice by DFAS.

(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 PCO). 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”. The COR will then send the validated PR via e‐mail back to the Contractor, who will then send the validated PR with three competitive quotes for each item to PCO for review and approval.

For filing purposes the subject of the e‐mail will be, “EAGLE TASK ORDER xxxx— Validated Contractor Purchase Request”. 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 xxxx—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 7 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 8 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 the COR or PCO. The Contractor will not submit any invoices for payment that have not been approved by the PCO.

(c) 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. Any line item that exceeds 15% of the original estimated cost that was initially validated by COR will need to be resubmitted by the Contractor to COR for revalidation before the PCO will conduct its review. The PCO will review the PR for appropriateness regarding price reasonableness and assuring the contractor follows 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 of the invoice, the PCO will concur on the invoice and provide to the contractor to input into WAWF for DCAA’s review and ultimate approval/disapproval in WAWF. The PCO has 3 days to provide concurrence after receipt of the COR validation of the invoice.

(d) Defense Contract Audit Agency (DCAA)

Role: Independent auditing of contractor invoices.

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

(5) SUMMARY

This document provides a detailed description of the initiation, validation, approval and archival of financial documentation expected on EAGLE Task Order 0001. As the effort progresses it is expected that the PCO and CORs, will recognize opportunities for efficiency improvements in the purchasing and invoice process. As those efficiencies are identified it is the responsibility of those parties to re‐evaluate this guide as appropriate.

(6) SAMPLES

The following sample Documents are found on the proceeding pages:

a. Blank Procurement Contracting Officer Consent Request

b. Blank Purchase Request Document

ADVANCE NOTIFICATION, PCO CONSENT Log #_ _

ADVANCE NOTIFICATION, PCO CONSENT

Submittal Date _________________________ To: From:

Agency Company Address Address

Person Person Title Title Phone Phone E-mail E-mail

Document Purpose PCO Consent to Subcontract

Prime Contract Data Prime Contract Number

Prime Contract Name Prime Contract Task Order Number

Prime Task Order Name Prime WBS Number(s)

Prime Contract Consent Threshold Prime Contractor Data

Procurement System has Approved Status Yes No Notification/Consent Package Data

PO/Subcontract No. or Class of Items Task Order/Modification Number

Description Value - Was

Value – This action Value - Total

Period of Performance Vendor

Vendor Location (city, country) Pricing Type (FFP, CPFF, T&M, etc.)

Required Placement before adverse impact

Criteria FAR Part 44.2-Consent To Subcontracts; Section 44.202-2 Considerations.

1. Is the decision to subcontract consistent with the contractor’s approved make-or-buy program, if any (see FAR 15.407-

2)?

2. Is the subcontract for special test equipment, equipment, or real property that are available from Government sources?

3. Is the selection of the particular supplies, equipment, or services technically justified?

4. Has the contractor complied with the prime contract requirements regarding-

a. Small business subcontracting, including, if applicable, its plan for subcontracting with small, veteran-owned, service-disabled veteran-owned, HUBZone, small disadvantaged and women-owned small business concerns (see FAR Part 19); and

b. Purchase from nonprofit agencies designated by the Committee for Purchase From People Who Are Blind or Severely Disabled (Javits-Wagner-O’Day Act [41 U.S.C. 48]) (see Part 8)?

5. Was adequate price competition obtained or its absence properly justified?

6. Did the contractor adequately assess and dispose of subcontractors’ alternate proposals, if offered?

7. Does the contractor have a sound basis for selecting and determining the responsibility of the particular subcontractor?

8. Has the contractor performed adequate cost or price analysis or price comparisons and obtained accurate, complete, and current cost or pricing data, including required certifications?

9. Is the proposed subcontract type appropriate for the risks involved and consistent with current policy?

10. Has adequate consideration been obtained for any proposed subcontract that will involve the use of Government-provided equipment and real property?

11. Has the contractor adequately and reasonably translated prime contract technical requirements into subcontract requirements?

12. Does the prime contractor comply with applicable cost accounting standards for awarding the subcontract?

13. Is the proposed subcontractor in the Excluded Parties List System (see FAR Subpart 9.4)?

Procurement Contracting Officer (PCO) Consent Request is;

Approved Disapproved

Comments:

PCO Name (Type/Print)

PCO Signature

Date

Attachments:

(1.)

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 #