Per SAP, when you use Evaluated Receipt Settlement, you agree with the vendor that they will not submit an invoice in respect of a purchase order transaction. Instead, the system posts the invoice document automatically on the basis of the data in the purchase order and goods receipt. I am trying to reconcile this process with regulatory guidance. Our contracting shop deals primarily with commercial acquisitions above the SAT for Firm-Fixed Price or FP-EPA. Per FAR, we cannot tailor provisions and clauses, in commercial acquisitions, in a way that is inconsistent with commercial practices, without a waiver. Traditionally, invoices are submitted for payment. Per FAR, due to the implementation of statutory requirements, provisions and clauses relating directly to payment and invoice shall not be tailored. This process improvement would directly impact the invoice requirement in FAR Part 12.
There are similarities between ERS and Fast Pay; however, Fast Pay is a feature of Simplified Acquisitions and places a limit at $25K per invoice, which we would definitely exceed. Under Fast Pay, invoices are examined after payment but the risk of overpayment is mitigated because the projected losses would be less than the administrative cost of examining all invoices.
There is also a concern about how this would affect Prompt Pay which is based on when the invoice is received. If the invoice, claim against the government, is not received by the vendor, it seems that Prompt Pay would come in at the time the recipient received the goods. Payments could be made sooner if there is no discrepancy between what the vendor intends to send versus what the recipient claims to have received and what is on the purchase order. Physical documents, like shipping documents, would not be reviewed unless there were a discrepancy.
Please provide feedback on removing the requirement for vendors to submit an invoice, under a commercial acquisition. Also, automating payment, without verifying documents, if the goods, the vendor intends to ship, the recipient receives, and the purchase order prescribes, all align within our automated system.