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For those of you who have had recent annual surveillances by your ACO/CACO (or delegate)... (1) how many PO files have they requested? 2) how formal has the surveillance process been (e.g., is there a report, expectation of a reply, and a final determination)?, and 3) how long has the reviews lasted (e.g., # of days, # of weeks, # of months)? Thank you for your help!
Brief Background: Our DCMA/CACO requested hard-copy of 45 PO files (initially requested 70) in preparation for a surveillance review. We have an approved purchasing system that is 100% electronic/paperless. We've had a paperless SAP system since 2011. Question: Is there a regulation or guidance that supports the DCMA/CACO request? If, No... how would you suggest we respond to our CACO without upsetting him? He has threaten to recommend a full CPSR if we do not provide the hard-copy PO files.
I'd be interested to know how Operational DoD offices have been handling the surveillance requirements for construction contracts. Under FAR 46.4, - Quality assurance surveillance plans should be prepared in conjunction with the preparation of the statement of work. Under DFARS 246-401 - For contracts for services, the contracting officer should prepare a quality assurance surveillance plan to facilitate assessment of contractor performance, see 237.172. ... (this seems to imply FAR 37 Service contracting - does FAR 37 Service contracting include construction? Under Subpart 37.3 - it discusses Demolition and Construction Wage Rates - it seems the argument on whether Construction contracting can be considered a Service is becoming more obscure, instead of clear). DoDi 5000.72 - Table 2 (Minimum requirements for Types A, B, and C training are described in Tables 2, 3, and 4, respectively.) infers that a Surveillance Plan is required. Perform technical and administrative contract surveillance and reporting responsibilities in accordance with the letter of designation and surveillance plan. However in DoDi 5000.72 - Table 1 it suggests a QASP only under performance-based services (not mentioning a QASP anywhere else in the DoDi). 24. For a performance-based services contract, order, or agreement, perform on-site surveillance in accordance with the QASP Otherwise, the DoDi is silent on surveillance. Does this mean the agency should determine their own surveillance requirements for construction? There doesn't seem to be anything written that says we shouldn't build a QASP in conjunction with construction Statement of Works. But for those that do construction contracting, it seems redundant to do so. In fact, the entire COR designation requirement for construction seems redundant since the majority of Program Managers already perform inspection (blue books, daily inspection logs, etc IAW with their own internal Civil Engineering procedures... which are ultimately handed over to contracting as part of the close-out file). How do your office handle surveillance?