Federal Acquisition Regulation (FAR) 31.201-2(d) states:
A contractor is responsible for accounting for costs appropriately and for maintaining records, including supporting documentation, adequate to demonstrate that costs claimed have been incurred, are allocable to the contract, and comply with applicable cost principles in this subpart and agency supplements. The contracting officer may disallow all or part of a claimed cost that is inadequately supported.
To comply with requirements, each subcontract file should contain the following information:
- The approved purchase requisition
- The written solicitation (where required)
- The written responses to requests for proposals or requests for quotations
- A memorandum justifying sole-source procurement (if no competition)
- A technical evaluation
- A price and cost analysis
- A memorandum of negotiations
- The basis of the award form
- A copy of purchase orders or subcontracts and all change orders
- Insurance certifications
- Copies of suppliers’ invoices
- Correspondence, internal and external, related to the purchase order and subcontract
- Other purchase order and subcontract documentation as required by the purchase orders and subcontracts’ terms and conditions
- The final contractor release forms
- A procurement documentation checklist indicating the documentation in the file
General Recommendations
- Develop an adequate records system to support claimed subcontract costs and verify the contractor’s completed actions.
SOURCE: AUDIT REPORT NO. E-267-11-002-P MAY 16, 2011
The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations. Please see the disclaimer of this site before using recommendations.
- Implementer Performed Unauthorized Program Activities - ADS 202.3.6.1
- Ensure That Funding Requests Are Appropriate - ADS 602.3.2
- Strengthen Oversight of Renovation Activities - FAR Part 36, “Construction and Architect-Engineer Contracts” - GAO/AIMD-00-21.3.1 (11/99), page 20
- Mission Did Not Complete Contractor Performance Review - USAID Acquisition Regulation 742.15 (also known as 48 CFR 742.1502) - FAR 42.1502
- Contracting Officials Did Not Document Contract Files or Communicate Adequately - 22 CFR 226 - FAR 4.801 (b)
- Fixed-Amount Reimbursement Agreements Reduce Risk - ADS Supplemental 317
- Contract Not Adequately Reviewed by Contract Review Board - (ADS) 302.3.1.2 - Contract Review Board Guidelines
- Questionable Spending Occurred - Federal Acquisition Regulations 52.216-7 and 52.216-8 USAID Acquisition Regulation 752.7003 FAR Subpart 31.2-Contracts with Commercial Organizations
- Contracting Mechanism Used for Program is not Appropriate - Federal Acquisition Regulation 16.505(a)(2) - supplemental policy to ADS 302, Indefinite Quantity Contract (IQC): Task Order Work Statement Development Checklist - Competition in Contracting Act
- Lack of Effective Program Oversight - ADS 302-Procedures for Designating the COTR for Contracts and Task Orders - ADS 303- Agreement Officer’s Technical Representative (AOTR) Designation – Cooperative Agreement Administration.
- Voluntary Population Planning Language Was Not Included in Subcontracts - USAID Acquisition Regulation (AIDAR) 752.7101, Voluntary Population Planning Activities
- Appropriate Records Were Not Retained - Federal Acquisition Regulation (FAR) 52.215-2, Audit and Records – Negotiation
- Source Origin Requirements Were Not Met - ADS 310, Source, Origin, and Nationality of Commodities - the Foreign Assistance Act Section 604 - ADS 310.5.5
- Approval for Subawards Was Not Obtained - 22 CFR Part 226, Administration of Assistance Awards to U.S. Non-Governmental Organizations, Section 226.25(c)(8)