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  1. I looked at that language, yesterday. I thought I would ask to see if anyone came across this situation because processes seem to be moving toward more automation.
  2. The vendors that we purchase from deliver directly to the recipient. The recipient inspects (counts quantity and condition) and enters this information into our system. I'm wondering if the information is already entered into the system, if we are required to check a hard document. This document is uploaded, by the vendor, along with their invoice. Acceptance happens when our contracting staff receives delivery document, with invoice, and checks it against what the recipient has reported.
  3. Can acceptance be made just based on what the recipient enters as confirmation of goods into our automated system? Currently, the vendor enters information about what they will ship and the recipient confirms. Acceptance happens after receipt of delivery reports and invoice. The confirmation of goods is crossed checked against the invoice and supporting documents. Can we accept goods based off what the recipient enters without crosschecking against supporting documents?
  4. GAO released, Streamlining the Payment Process While Maintaining Effective Internal Controls, in May of 2000. GAO was asked whether it would be permissible to make payments, under purchase order acquisitions, without a vendor's invoice solely on the basis of a receiving report or other documentary evidence showing receipt and acceptance. They reviewed the proposed process and responded stating, Title 7 does not preclude payments from being authorized without an invoice if adequate internal controls exist such as: 1)payment initiated after receipt and acceptance 2) controls against duplicate payment 3) payments coincide with due dates. I assume FAR 12.302(b), which prohibits tailoring...under any circumstances, would trump this feedback from GAO.
  5. I was referring to the software company's description of their ERS process.
  6. 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.
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