Jack Russell

I do appreciate the responses and realize that there is probably no definitive answer, but you have definitely stimulated my thought process and encouraged me to explore different ideas on how to approach this.....since there is more than one way to verb a noun (PETA approved phrase). For the record "The invoice shall contain all information required in other sections of this task order, including, FAR 52.216-7 (Allowable Cost and Payment) (for Materials portion of T&M only) and FAR 52.232-7 (Payments under Time-and-Materials and Labor-Hour Contracts)." Now, I will probably really make it interesting since interestingly enough, one of the contract deliverables was submission of an Invoicing Plan at the beginning of the contract which incidentally mentions none of this required documentation: The Contractor shall continue to provide an invoicing plan to ensure that billings are accurate and timely. The plan shall be submitted at TO start to demonstrate the ability to: a. Establish process for submitting, approving, and processing invoices (other criteria are added, but none specific to this discussion).

Thank you all for the replies. You have given me a lot to research and a lot to think about. I am in awe of the knowledge on this board. The SOW of the contract states that in general, the Contractor shall first obtain approval for any PR by the COR/GTM prior to any procurement for items currently authorized under the contract $10,000 or above. Secondly, the resulting Purchase Order shall not deviate from the terms and conditions listed in the PR. If there are changes, the Contractor shall submit a revised PR. Under no circumstances shall a procurement be made before a PR is approved. Thirdly, no product or service can be invoiced until goods and services are received. Accordingly, the Contractor shall advise the COR/GTM that goods and services have been received and the COR/GTM shall inspect, validate, and verify. The COR/GTM shall sign-off on the Receiving Report so that the Contractor may submit for invoicing. It is my contention that the COR inspecting, validating, and verifying only applies to purchases above $10K as outlined above. He is taking this to mean no product or service can be invoiced until he has inspected, validated, and verified when to me it is obvious that the words secondly and thirdly indicate that the conditions are linked to and applying to the first sentence which refers only to purchases above $10K, but others may see it different because it is somewhat ambiguous. I hope that I am making sense and thank you again for your input and patience.

Hi Joel, these purchases are mainly ODCs for training activities under the T&M portion of the contract. A few are under the FFP portion, but not many.

Thank you for approving my membership. While I always try to find answers to my questions from the FAR or other regulatory guidance the one addressed below is a bit of a challenge. I work for a contractor with a large government contract in Afghanistan. Our contract requires client approval for any purchase over the MPT which is bureaucratic enough. I am now faced with ‘technical direction” from the COR where after receiving goods or services regardless of price, that I am to submit (1) a DS 127 Form (Department of State Receiving and Inspection Report) signed by me, (2) the invoice, (3) photos of the goods received or attendance sheets for events or other supporting documents, boarding passes, flight tickets, etc. (4) procurement request, (5) all quotations received, (6) evaluation documents if over $500, (7) RFQ, (8) results of restricted party checks, (9) Vendor Business License, (10) Vendor Bank Account Information, (11) any required approvals, (13) modifications, and (14) various other documents. The COR has his contract assistants scrub these documents looking for any inconsistencies and if good, signs off on the DS 127 which is returned to me and then processed by me for the billing cycle. I have sent in these packages for purchases of less than $20 and when questioned on why this was being required when there was no contractual basis, the response was that all contracts in Afghanistan are audited by the SIGAR and OIG and the COR needed to show that the government actually received/took possession of the goods/services regardless of cost. When I mentioned that the administrative cost of verifying that the goods/services were received may more than offset potential savings from detecting instances of goods/services not being received, I was basically told that this was the requirement. I now have a local employee who does nothing but prepare and track these packages. The contract is a hybrid FFP and T&M. I have never come across this requirement before for micro-purchases and again the COR’s contention is that he has to show that the government actually took possession of the goods/services even though many are consumables: meals, refreshments, lodging, etc., received by a contractor (my project) through the course of implementing the contract. This has been brought to the attention of the CO without any action taken. Does anyone have any comments on a way around this?