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Hello, 

My office peers use an excel spreadsheet that they use to track invoicing. Every time they approve an invoice in the system they log it on this spreadsheet and put it in the file. When I asked why we do this spreadsheet I did not receive an answer other than "this is just how we have always done it". Is their a FAR or DFARS requirement that invoicing must be tracked in this manner? I could not find anything and was wondering what your offices do. 
 
Thank you!
 
 

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I cannot speak for the DFARS since I have not worked in DoD for many years, but there is not a requirement in the FAR.  I very much doubt there is one in the DFARS.  It is probably a local practice and may or may not even be in a policy in your office or the DoD agency you work for.

It is sometimes helpful to have the invoice information summarized on a spreadsheet in case you or someone else looking at the file needs to review the invoices.  I've done it for some of the larger contracts that I've had where invoices are received routinely (e.g., bi-weekly, monthly, etc.).  Also, if there is an automated invoicing system used by your agency, as is the case within the agency I work for, I'd consider just running a report out of that system periodically rather than maintaining a spreadsheet, so long as it had all the information on it that I wanted.

I like to do things for a reason and not solely because "that's how we've always done it."

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44 minutes ago, ContractingPeoplesHatred said:

"this is just how we have always done it"

A phrase used by far too many contracting professionals when explaining decisions from acquisition planning through source selection and contract admin.

One can only hope that they will engage their brains to read the regulations and discern business practices as well as they engage their fingers to enter their automated procurement systems.

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I would hope that your automated system for payments would give you any report you might want.  I agree that nothing in the FAR requires it.

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I wonder if the spreadsheet could be used in the event a contractor asserts it is due Prompt Payment Act interest? Then the spreadsheet could show that the invoice was approved timely ... even though it took additional time at DFAS to process the payment. Just a thought ...

This could be a useful tool if it did more than track invoice dates and payment amounts. If it reflected ACRN payment information it could be used to cross-check DFAS payments by ACRN, and then used at close-out as a tool to help reconcile and correct DFAS, MOCAS, and contractor records.

But that would be too much work, I bet.

 

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I have seen the requirement to maintain such a log specified in COR appointment letters. For fixed price contracts it is usually not a big deal, however for Time and Materials and Labor Hour contracts, and I would assume also for Cost contracts, it is a bit more important. CORs are/were to use such a tracking mechanism to verify that sufficient funds remain on the contract to pay invoices that are submitted. While the tracking spreadsheet is not the "official record" of the balance of funds, the payment system is, it certainly should be a quick way to ascertain whether funds remain to pay the invoice. While you could go into the automated payment system to determine if funds remain, that is usually much more work than having a properly maintained spreadsheet that can be used to quickly see how much money is left.  For example, the Army now uses the General Funds Enterprise Business System (GFEBS) as their payment system. To go into GFEBS to validate the balance of funds would take between 5 - 10 minutes per contract, depending how proficient you are with the system, and what information you had to begin with (having the contract number would typically not be enough to quickly get to the data you are searching for).  You could do the same thing within a couple of minutes if you use a tracking spreadsheet.  In the DoD Agency I now work with, neither the CORs or the contracting office even has access to the payment system to verify remaining funds, so a spreadsheet maintained by the COR is even more important.

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Here's a thought--

Instead of contracting office staff keeping these spreadsheets, why not simply require that the contractor's invoice include a spreadsheet correctly detailing all the previous invoices and payments under the contract?  Then, providing the correct spreadsheet becomes a matter of a proper invoice.

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8 minutes ago, ji20874 said:

Here's a thought--

Instead of contracting office staff keeping these spreadsheets, why not simply require that the contractor's invoice include a spreadsheet correctly detailing all the previous invoices and payments under the contract?  Then, providing the correct spreadsheet becomes a matter of a proper invoice.

ji,, that is not a condition of the contract payment or prompt payment clauses in order to be paid or to be considered an "acceptable invoice". And - why pay additional taxpayer funds, if applicable,  to require a contractor to perform that additional effort?  A contractor likely won't know when the KO or COR approved the invoice for payment, if the government is using internal software system for payments.

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3 minutes ago, ji20874 said:

Here's a thought--

Instead of contracting office staff keeping these spreadsheets, why not simply require that the contractor's invoice include a spreadsheet correctly detailing all the previous invoices and payments under the contract?  Then, providing the correct spreadsheet becomes a matter of a proper invoice.

You could do that. I have never seen the contracting office "keep" these spreadsheets, it was the CORs who kept them, although they were part of the COR file that is available to the contracting office.  Here is a real world scenario where having the contractor provide the spreadsheets with each invoice would be problematic. You have a service contract that involves a lot of travel under a Cost CLIN. When I say a lot I mean 30 - 60 trips a month. The contractor is required by contract to submit travel requests to the COR for approval prior to travel. The travel requests includes among other information the estimated cost for the trip. Prior to approving the travel the COR is required to verify funds remain to cover the projected travel costs. Since billing occurs after the travel is completed, the payment system or the spreadsheet submitted by the contractor with their previous invoice, will not reflect travel costs that have been incurred, but have yet to be billed. Maintaining the invoice spreadsheet allows the COR to log each of these travel requests as they come in, and verify that sufficient funds remain the cover the next trip. I guess you could require that the contractor submit am up-to-date spreadsheet with each travel request if you wanted to. 

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We spend taxpayer dollars all the time to get contractors to do stuff for us -- that's what the FAR is all about.

A contract could require a funds/payments report as a condition of a proper invoice.  For example, see para. (a)(1)(x) of the clause at FAR 52.232-25, Prompt Payment.

Just a recommendation...  of course, it might not fit for EVERY circumstance and contract.

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17 hours ago, ContractingPeoplesHatred said:

My office peers use an excel spreadsheet that they use to track invoicing.

What kind of office do you work in? What do your "peers" do? What kinds of invoices are you talking about? Invoices for what kinds of work under what kinds of contractual instruments? Tracking for what? Receipt? Review? Approval? Forwarding?

Clearly, a CO or CS working in a DOD system program office is not using an excel spreadsheet to log payments to Boeing or Lockheed Martin. But someone working in a small contracting office reviewing and approving invoices for calls against blanket purchase agreements might be.

In short, what the heck are you talking about? Do you think that all contracting offices are doing the same kinds of procurements?

If all your "peers" are doing is reviewing and approving invoices for payment, then it makes perfect sense to me for them keep logs of what they have received, reviewed, approved, and forwarded if they don't have an automated system for that purpose.

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17 hours ago, ContractingPeoplesHatred said:

Is their a FAR or DFARS requirement that invoicing must be tracked in this manner?

There is not a FAR/DFAR requirement as noted by others in the thread but the FAR does provide the following guidance (see below).   Noting the FAR wording it is not a requirement but again guidance.   Within the same subsection of the FAR the guidance provides that there can be cross reference in the “Contracting Office contract file”  to documents filed elsewhere.   As noted in this thread the move to electronic payment tools and databases has probably replaced the need for your office (aka the Contracting Office) to follow "just how we have always done it” and to make a simple cross reference to where the detail on payments is now stored (“contract paying office”) which would meet the guidance intention.  I say this noting that it would be hoped that your agency’s payment system documentation requires retention of the payment information consistent with the retention of contract records after completion and final payment is made for a contract.   See FAR 4.805 for the guidance on retention. 

Armed with this basic information and a little more detail research effort on your part in researching your agency FAR supplements and policy on contract records you might consider proposing an alternative to the spreadsheet which appears to be duplicative effort.  

4.803 -- Contents of Contract Files.

The following are examples of the records normally contained, if applicable, in contract files:……

 (c)Paying office contract file.

(1) Copy of the contract and any modifications.

(2) Bills, invoices, vouchers, and supporting documents.

(3) Record of payments or receipts.

(4) Other pertinent documents”

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The FAR does not tell you how to manage an office!!!!!

Not all office activity is part of acquisition, per se, and keeping records of some kinds of internal office actions and external transactions is a just matter of competent office management.

  • Ever see a board on which people sign in and out of the office? That's not prescribed by FAR.
  • Anyone log telephone calls about official business? That's not prescribed by FAR.
  • Anyone keep a list of assigned action items? That's not prescribed by FAR.
  • Anyone keep a project diary? That's not prescribed by FAR.
  • Anyone keep a calendar of upcoming meetings? That's not prescribed by FAR.

Some things are just smart to do, whether anyone tells you to do it or not.

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To add to Vern's list of questions,  what do you mean by invoice?  That term is  frequently used somewhat loosely to describe many types of payment requests and the FAR uses it to describe various types of payment requests.

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