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1. Risk Planning
1.1. Receive the Contract - This process begins with CMO receipt of a prime contract, support (including non-DoD) contract, support delegation, Other Disbursing Office (ODO), or similar document.
1.2. Establish File and Distribute the Contract - An official contract file shall be established. For contracts under $100,000, offices may simply maintain copies of contracts, and establish more detailed files by exception, when deemed appropriate to document specific contractual issues. Refer to FAR 4.802, FAR 4.803(b), DFARS 204.802. The Electronic Document Workflow (EDW) system makes distribution of contracts and modifications to the appropriate personnel based on the CMOs system workflow tables. CMOs are encouraged to develop and implement effective risk-based methodologies for contract review. CMO workflows and procedures shall effectively identify contracts representing significant acquisition risks, and ensure that contracts and modifications are distributed in a timely manner to the appropriate personnel for their review.
2. Risk Assessment
New DoDAACS for Defense Logistics Agency (DLA) Contracts Issued by Business System Modernization (BSM) (INFORMATION)
2.1. Review the Contract. Contracts are reviewed as necessary to gain an understanding of contract requirements. In some cases, a CMO Post Award Orientation (PAO) may be necessary. When determining whether a post award orientation is necessary and, if so, what form it shall take, the ACO should following the guidance at FAR 42.502 and may create post award documentation documents (PAOD) using the Contract Reciept and REview (CRR) eTool. Additionally, data integrity reviews are appropriate when the CMO has reason to doubt the accuracy of data entered in the Mechanization of Contract Administration Services (MOCAS)/System for Integrated Contract Management (SICM) (e.g., manually input contracts). Data integrity reviews provide CMOs an early opportunity to get data entry and appropriations errors corrected, thereby avoiding future payment, delivery, canceling funds, and contract closeout problems, all of which are important to customers. Guidance is provided in the CRR Users Guide. Additional guidance is available that is peculiar to different types of contracts.
DSCR Post Awards Contract Administrator Locator Web Page (INFORMATION)
Warner Robins Part B Purchase Orders With Option Year Quantities (INFORMATION)
Contracts involving aircraft or contracts which contain either the Ground and Flight Risk Clause DFARS 252.228-7001 or the Flight Risk Clause DFARS 252.228-7002 require specialized review by designated aircraft operations personnel. If the CMO does not have an assigned Government Flight Representative, the CMO will coordinate with DCMA-AO for review of the contract and to determine the correct CMO to delegate the aircraft operations function to based on contract type and geographic location.
2.1.1. When contracts contain industrial security requirements, the ACO should forward information to the appropriate contractor's security office, confirm contractor understanding that the responsibility to safeguard classified information is a continuous process from contract award to closeout, and that the contractor is in compliance with the DD 254 guidance.
2.1.2. When a CMO becomes aware of a contract or modification that has not been received, CMO personnel shall promptly request a copy of the contract from the buying command. On MOCAS contracts paid by DFAS where the contract/modification has been received and is unprocessed, the Administrative Contracting Officer (ACO) or designated functional specialist shall promptly ask DFAS to input the contract document. CMOs should consider maintaining a log of contracts sent to DFAS for input and perform periodic followup to assure that contract is entered. Note that DFAS Columbus is responsible for MOCAS input of MOCAS-paid PCO-issued documents, while DCMA is responsible for MOCAS input of ODOs and ACO issued orders/modifications. (V)
2.1.3. The term ODO (other disbursing office) refers to contracts paid by other than the DCMA primary payment system (MOCAS). If the contract is an ODO or System for Integrated Contract Management (SICM) contract, the CMO shall ensure that the contract is input to MOCAS as well as the appropriate database. For additional information on ODO contracts, refer to ODO guidance.
Modification Process for DLA SAMMS Contract Closeout (INFORMATION)
DLA Procurement Technical Assistance Center (PTAC) Contracts (INFORMATION)
2.1.4. When database corrections/updates are required as a result of the review or to clear a MOCAS Backlog Listing, the appropriate CMO functional specialist (e.g. IS, CA, PT) inputs the corrections locally. For changes outside the scope of their access, requests should be forwarded to the CMO trusted agent for input. If necessary, the trusted agent will forward to DFAS those corrections requiring DFAS action. Guidance regarding DCMA responsibilities for database corrections, ship-to field corrections, and the input of classified information are included in the Trusted Agent Manual.
2.1.5 Contractual documents and support delegations shall be subjected to timely CMO reviews. The primary purposes of this initial review upon contract receipt is for the CMO to identify and understand contract requirements, and to help determine if a Post award Orientation Conference (PAOC) is necessary. (NOTE: Other Process Guidance, e.g., Supplier Quality Assurance, may require more detailed reviews of technical requirements, e.g., technical drawings and specifications, to be completed at a later time.)
3. Risk Handling (not applicable)
4. Risk Monitoring
4.1. CMOs will evaluate and apply appropriate risk monitoring options to coincide with overall risk to performance, schedule, and cost, or employ new risk monitoring options if current ones prove ineffective.
4.2. Contract deficiencies discovered by DCMA after contract award should be discussed with the contractor when appropriate, and reported by the most efficient means (e.g., EDA-CDR Application, e-mail, DD form 1716) to the ACO/PCO for official resolution.
4.3. The ACO will respond to DFAS-issued Contract Deficiency Reports (CDRs). ACO-issued modifications written in response to a CDR shall include a reference to the CDR control number in the modification. All CDR responses shall also contain the number of the modification issued as a result of the CDR.
4.4. CMO Post Award Orientation Determination. CMO PAODs are not mandatory for contracts (including ODOs) valued at less than $100,000. For all basic ordering agreements (BOAs), non-procurement instruments (NPIs), and contracts $100,000 and over, if the PCO does not call for a PAOC, the ACO/Administrative Grant Officer (AGO) shall decide the CMO position on whether a PAOC is necessary. A PAOD is not required on Indefinite Delivery Type Contract (IDTC) task/delivery orders; only the Basic Instrument requires a CMO PAOD. A PAOD is also not required at locations where routine Government-contractor meetings (covering the same concerns that would have been covered in PAOCs) make PAOCs unnecessary. For Other Transactions (OTs) $100,000 and over, if the issuing office does not require a PAOC, the AGO shall make the CMO PAOD. For information on arranging for and conducting PAOCs, refer to the Supplier Risk Management Guidance.
5. Risk Documentation
5.1. There are no mandatory documentation requirements for contract reviews or Post Award Orientation Determinations, but two optional formats are available for documenting the requirements review (the Modification Index and the CRR PAO Limited (Requirements Review) document found under the CRR eTool). When a post award orientation conference is conducted, the ACO may use the CRR PAO Limited or Detailed documentation (found under the CRR eTool) or some other convenient form in preparing the conference report (see FAR 45.503 and DFARS 242.5). |
