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Vern Edwards

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Posts posted by Vern Edwards

  1. Continuing resolutions, unlike government shutdowns, are routine. The following is from a Congressional Research Service report published in 2000:


    Continuing resolutions date from at least the late 1870s, and have been a regular part of the annual appropriations process in the post World War II period. In fact, with the exception of FY1989, FY1995, and FY1997, at least one continuing resolution has been enacted for each fiscal year since 1954. (However, the two FY1977 continuing resolutions did not provide funding for an entire regular appropriations bill. Instead, they provided funding for only selected activities.)

    Until the early 1970s, continuing resolutions principally were limited in scope and duration, and rarely exceeded a page or two in length. They were used almost exclusively to provide temporary funding at a minimum, formulaic level, and contained few provisions unrelated to the interim funding.

    Beginning in the early 1970s, conflict between the President and Congress over major budget priorities, triggered in part by rapidly increasing deficits, greatly increased the difficulty of reaching final agreement on regular appropriations acts. This conflict led to protracted delay in their enactment. Continuing resolutions, because they historically have been viewed as "must-pass" measures in view of the constitutional and statutory imperatives, became a major battleground for the resolution of budgetary and other conflicts. Consequently, the nature, scope, and duration of continuing resolutions began to change.

    Footnotes omitted.

    See "Continuing Appropriations Acts: Brief Overview of Recent Practices," 2000. Google it.

    Democracy is messy. Always has been, always will be, and it's getting worse every year in "democracies" all over the world. Sometimes it just doesn't work.

    The question is, Why? Does the problem lie with the nature of democracy or with the people being governed?

  2. In the interest of professional education, some last thoughts.

    • What is a "note"?
    • Why make ("take") them?
    • Are there different kinds of notes (lecture, reading, observation, discussion, interview... )?
    • If so, do they have different kinds of contents, styles, and formats? Are there standards?
    • How do you make notes?
    • Do your evaluators know what "good" notes are and how to make them?
    • Do you?

    Believe it or not, there is a voluminous literature about all that.

    Making notes is something people take for granted, because they figure they know how to do it.

    But do they?

    Most people receive no formal instruction in note-making. 


    Anyone heard of Niklas Luhmann and the Zettelkästen note-taking method?  https://en.wikipedia.org/wiki/Zettelkasten

    Thomas Edison produced more than 3,000 200-page notebooks.

    Lawyers keep trial notebooks. What do they put in them? See https://www.fastcase.com/secondarymaterials/building-trial-notebooks/ and https://www.blumberg.com/downloads/TrialNotebook.pdfhttps://www.illinoistrialpractice.com/2004/05/a_method_of_org.html

    Should COs keep (a) source selection or (b) contract/modification negotiation or (c) claim/dispute resolution notebooks? Should CORs keep contract admin notebooks?


    Take care, all.

    We're getting older. Don't waste time. Be more knowledgable and smarter than the others in your office.

  3. @formerfed

    Because it's you, and because we were members together for so long, I'll respond to your last two posts..

    My post focused on the record retention requirements of 44 USC 3301, et seq, and the NARA regs, as distinct from GAO case law. See FAR 1.602-1(b). But you can see the importance of retaining documentation in the GAO decisions. What do they say about evaluators's notes?

    A search of GAO decisions for the words evaluators and notes in a single sentence turned up 75 hits between 1976 and 2023. See, for example, Accenture Federal Services, LLC, B-421134.2, April 12, 2023. The issue was evaluators' notes taken during oral presentations:


    Finally, Accenture challenges the agency's evaluation of proposals under the technical evaluation factor, asserting that, because the agency chose not to record the oral presentations, there is “no adequate record” of those presentations and maintaining “[t]his is in plain violation of FAR 15.102(e).” Second Supp. Protest at 22; First Supp. Protest at 32 n.8. More specifically, Accenture asserts that there is “no written record” regarding the offerors' responses to the “on-the-spot” scenarios, characterizing the evaluators' contemporaneous notes as “rang[ing] from completely illegible chicken scratch to legible but uninformative and ambiguous bullets.” First Supp. Protest at 49, Second Supp. Protest at 22.

    We reject Accenture's assertion that the agency's documentation of oral presentations was inadequate. First, Accenture's reliance on the provisions of FAR part 15 is misplaced, since this task order procurement was conducted under the procedures of FAR subpart 16.5, which provide for a streamlined procurement process requiring less rigorous documentation.27 Our Office recently discussed the extent of an agency's obligation to document oral presentations in a FAR subpart 16.5 procurement under facts that are strikingly similar to those presented here. See Booz Allen Hamilton, Inc., B-419210, B-419210.2, Dec. 22, 2020, 2020 CPD ¶ 409 at 4-5. There, the solicitation (also issued by the Department of Homeland Security) required offerors to make oral presentations that were not recorded, but during which the agency evaluators took notes; permitted offerors to submit a limited number of slides addressing five questions disclosed in the solicitation, but also required responses to undisclosed “on-the-spot” and “scenario-based” questions; and subsequently prepared an evaluation report. Id. at 2-3. There too, the protester asserted that the agency's decision not to record the oral presentations resulted in an inadequate record of the oral presentations. We denied the protest, concluding that the combination of offerors' slides for a portion of the oral presentations, evaluator notes, and a subsequent evaluation report complied with the requirement for the agency to create an adequate record. Id. at 4-5.
    Here, the offerors submitted written slides responding to the scenarios disclosed in the solicitation. Further, with regard to the “on-the-spot” scenarios, the agency evaluators created 60 pages of notes; discussed each offeror's presentation immediately after the presentation; and subsequently prepared an evaluation report documenting the basis for the assigned ratings. We have reviewed the record, including the evaluator notes and the evaluation report, and find no basis to meaningfully distinguish the facts presented here from those we considered in Booz Allen Hamilton. Accordingly, the protester's assertion that the agency failed to establish an adequate record of the offerors' oral presentations is denied.
    And that was just a "fair opportunity" competition. The protest was denied.
    Do you think those notes were "records" as defined by statute? If so, Why? If you think they were records, do you think 44 USC 3301 et seq and the NARA regulations require that they be retained in the file and not just summarized in a report? Do you think destroying them would be consistent with the law?
    And see Southwest Marine, Inc.; American System Engineering Corp., B-265865, January 23, 1996:

    Here, the Navy's destruction of the evaluators' notes and workpapers left a written record that did not meet the requirements of FAR § 15.608(a)(3)(ii). The contemporaneous documentation retained by the Navy—the TEC's final report, the TEC chair's cost/technical tradeoff document, and source selection decision—did not adequately explain why BAV's proposal was judged to be technically superior to SWM's and AMSEC's. Specifically, while the TEC report described BAV's proposal's strengths and advantages to justify its “highly acceptable” rating, it did not explain why the protesters' proposals, which appeared from this document to have similar strengths, were not essentially technically equivalent. Accordingly, the retained documentation was not sufficient to support the evaluation results. Indeed, a hearing was convened at our request, in part, because of the inadequacy of the evaluation documentation in the record, which did not fully explain the agency's evaluation, Tr. at 286–287, and the hearing testimony revealed that a number of identified strengths and weaknesses for all offerors' proposals were not recorded in the TEC's final evaluation report. Tr. at 336–338, 397–398.

    That protest was sustained. Now the GAO did that without reference to 44 USC 3301. But do you think, given the GAO's findings, that destroying those notes and workpapers was consistent with the records retention law?

    Now, yesterday, after I made my post and said that whether documentation constituted a "record" had to be determined on a case-by-case basis, you wrote:

    On 8/9/2023 at 11:41 AM, formerfed said:

    I stand by my prior comment.  If evaluators are instructed to read and/or listen to proposals, examine in light of the evaluation criteria, make notes and come prepared to discuss and produce a consensus report, the report of the only “record.”  That’s all that should be in the contract file.

    I shook my head when I read your response to my post. You wrote it as if there is a national standard for the content of consensus reports. Do you know of one? Did you do any research before coming back with that? Can you see now how your statement, which strikes me as overly broad, but coming as it did from an experienced veteran of contracting and Wifcon Forum might mislead and misdirect less knowledgeable readers? That kind of thing is why I warn readers that Wifcon Forum in not a reliable source of information for anyone other than the foolishly credulous.

    I can see that some of members of the Forum think hanging on to documentation is anal retentive. I can see that others fear that keeping documentation might reveal flaws in an evaluation and, like certain politicians, prefer to get rid of that which might be embarrassing. I don't expect to change such minds, but I want to provide information that might help others make sound decisions. As a former contracting professional, I happen to believe in transparent government and legal compliance. I don't think government employees should start taking bypasses from compliance.

    I don't think I have your current email address, but if you send it to me via the Wifcon Forum message channel, or through Bob, I'll send you a list of all 75 GAO decisions. And then you can decide if a consensus report, whatever information that might contain, is the only document that need be kept in the contract file.

    In any case, best to you.



  4. I no longer participate at Wifcon and I don't read the Forum anymore, but someone called me about this thread and, having read it, I have a few things to say.

    Here is the OP's original question:

    On 8/7/2023 at 2:53 PM, Voyager said:

    Established case law from GAO says this about source selection evaluators' notes: "[T]here is no requirement that an agency retain individual evaluator’s notes or worksheets, provided the agency’s final evaluation documentation reasonably explains the basis for the agency’s judgments." (Government Acquisitions, Inc., B-401048; B-401048.2; B-401048.3, May 4, 2009)

    44 U.S.C. 3301, however, requires agencies to retain all "records", which are defined and trained to very broadly include documents that "contain informational value as evidence of your organization's...decisions," or even just, "An original document related to agency business that does not exist elsewhere."

    Which of these do PCOs follow when deciding what evaluation documentation to retain in the official source selection file?

    Emphasis added.

    The question is based on false assumptions. There is no conflict between GAO case law and 44 USC 3301 with respect to retention of records, and there is no choice between compliance with the GAO case law and the statute in this matter. The proper response to the question asked  is that COs must always comply with the statute. As I hope to show, below, they will have no problems under GAO's case law if they do, because the case law is just an evidentiary policy and is less demanding than the statute. A CO might be okay under GAO case law, but not under a federal court's jurisdiction if they did not comply with statute.

    Now, with respect to 44 USC 3301, we must ask ourselves some questions

    1. What is a record?

    2. What records must agencies make?

    3. What records must agencies keep?


    According to 44 USC 3301:


    (a) Records Defined.-

    (1) In general.-As used in this chapter, the term "records"-

    (A) includes all recorded information, regardless of form or characteristics, made or received by a Federal agency under Federal law or in connection with the transaction of public business and preserved or appropriate for preservation by that agency or its legitimate successor as evidence of the organization, functions, policies, decisions, procedures, operations, or other activities of the United States Government or because of the informational value of data in them; and

    (B) does not include-

    (i) library and museum material made or acquired and preserved solely for reference or exhibition purposes; or

    (ii) duplicate copies of records preserved only for convenience.

    (2) Recorded information defined.-For purposes of paragraph (1), the term "recorded information" includes all traditional forms of records, regardless of physical form or characteristics, including information created, manipulated, communicated, or stored in digital or electronic form.

    That's pretty broad. The National Archives and Records Administration (NARA) has specified its implementation of the statute in Title 36 of the Code of Federal Regulations, Chapter XII, National Archives and Records Administration, Subchapter B, Records Management. According to the regulation, all Federal agencies must comply with Subchapter B.

    NARA elaborates on the statutory definition or record in 36 CFR 1220.18, What definitions apply to the regulations in Subchapter B?


    Records or Federal records is defined in 44 USC 3301 as including “all books, papers, maps, photographs, machine readable materials, or other documentary materials, regardless of physical form or characteristics, made or received by an agency of the United States Government under Federal law or in connection with the transaction of public business and preserved or appropriate for preservation by that agency or its legitimate successor as evidence of the organization, functions, policies, decisions, procedures, operations or other activities of the Government or because of the informational value of the data in them 44 USC 3301.” (See also §1220.10 of this part for an explanation of this definition).

    And see 36 CFR 1220.18:


    Adequate and proper documentation means a record of the conduct of Government business that is complete and accurate to the extent required to document the organization, functions, policies, decisions, procedures, and essential transactions of the agency and that is designed to furnish the information necessary to protect the legal and financial rights of the Government and of persons directly affected by the agency's activities.


    Documentary materials is a collective term that refers to recorded information, regardless of the medium or the method or circumstances of recording.

    Emphasis added.

    See further, 36 CFR 1222.10, How should agencies apply the statutory definition of Federal records?


    (a) The statutory definition of Federal records is contained in 44 U.S.C. 3301 and provided in § 1220.18 of this subchapter.

    (b) Several key terms, phrases, and concepts in the statutory definition of a Federal record are further explained as follows:

    (1) Documentary materials has the meaning provided in § 1220.18 of this subchapter.

    (2) Regardless of physical form or characteristics means that the medium may be paper, film, disk, or other physical type or form; and that the method of recording may be manual, mechanical, photographic, electronic, or any other combination of these or other technologies.

    (3) Made means the act of creating and recording information by agency personnel in the course of their official duties, regardless of the method(s) or the medium involved. [Emphasis added.]

    (4) Received means the acceptance or collection of documentary materials by or on behalf of an agency or agency personnel in the course of their official duties regardless of their origin (for example, other units of their agency, private citizens, public officials, other agencies, contractors, Government grantees) and regardless of how transmitted (in person or by messenger, mail, electronic means, or by any other method). In this context, the term does not refer to misdirected materials. It may or may not refer to loaned or seized materials depending on the conditions under which such materials came into agency custody or were used by the agency. Advice of legal counsel should be sought regarding the “record” status of loaned or seized materials.

    (5) Preserved means the filing, storing, or any other method of systematically maintaining documentary materials in any medium by the agency. This term covers materials not only actually filed or otherwise systematically maintained but also those temporarily removed from existing filing systems.

    (6) Appropriate for preservation means documentary materials made or received which, in the judgment of the agency, should be filed, stored, or otherwise systematically maintained by an agency because of the evidence of agency activities or information they contain, even if the materials are not covered by its current filing or maintenance procedures.

    And see 36 CFR 1222.12, What types of documentary materials are Federal records?



    (a) General. To ensure that complete and accurate records are made and retained in the Federal Government, agencies must distinguish between records and nonrecord materials by applying the definition of records (see 44 U.S.C. 3301 and 36 CFR 1220.18 and 1222.10 of this subchapter) to agency documentary materials in all formats and media.

    (b) Record status. Documentary materials are records when they meet the conditions specified in § 1222.10(b).

    (c) Working files and similar materials. Working files, such as preliminary drafts and rough notes, and other similar materials, are records that must be maintained to ensure adequate and proper documentation if:

    (1) They were circulated or made available to employees, other than the creator, for official purposes such as approval, comment, action, recommendation, follow-up, or to communicate with agency staff about agency business; and

    (2) They contain unique information, such as substantive annotations or comments that adds to a proper understanding of the agency's formulation and execution of basic policies, decisions, actions, or responsibilities.

    (d) Record status of copies. The determination as to whether a particular document is a record does not depend upon whether it contains unique information. Multiple copies of the same document and documents containing duplicative information may each have record status depending on how they are used in conducting agency business.


    Emphasis added. 


    See 44 USC 3101, Records management by agency heads; general duties



    The head of each Federal agency shall make and preserve records containing adequate and proper documentation of the organization, functions, policies, decisions, procedures, and essential transactions of the agency and designed to furnish the information necessary to protect the legal and financial rights of the Government and of persons directly affected by the agency's activities.


    Emphasis added.


    See 36 CFR 1220.30, What are an agency's record management responsibilities?


    (a) Under 44 USC 3101, the head of each Federal agency must make and preserve records containing adequate and proper documentation of the organization, functions, policies, decisions, procedures, and essential transactions of the agency. These records must be designed to furnish the information necessary to protect the legal and financial rights of the Government and of persons directly affected by the agency's activities.

    Emphasis added.

    Now suppose that an evaluator reading a technical proposal sees an assertion by the contractor of an engineering or scientific nature that she knows to be false based or more current research than the contractor has done. She scribbles a note to that effect and later shares that note with other evaluation team members during a team consensus meeting. Can the CO toss it after the announcement of the source selection decision? Should the CO tell evaluators not to make such notes?

    My conclusion: The determination of what constitutes a source selection "record" and the determination of which records must be retained must be decided on a case-by-case basis. I think best practice is to retain everything produced by the evaluation team, at least pending review. That's what I was trained to do almost 50 years ago, and I still believe that it is prudent practice. If you do, you'll comply with the law and you'll be okay in that respect with the GAO. If you don't, you might find yourself in difficulty in more than one way. And once something is gone, it's gone, unless you're hiding a copy.

    • I disagree with Don that "everything" is a record. That's too broad.
    • I disagree with ji20874 that the GAO case law is "correct." Correct about what? It's own evidence policy?
    • I disagree with ji20874 that individual evaluator notes are not records. That's too broad in the opposite direction from Don.
    • I also disagree with formerfed when he says, "The most prudent and wisest practice in my opinion is preparing a consensus report and that should be the only document retained." That's so unwise it's scary. And it's scary that Joel would agree.
    • And I disagree with Joel when he agrees with ji20874 that individual evaluator findings are not records

    There is a troubling failure of professionalism on the part of some of the veterans of this forum when it comes to responding to questions. Too much opinion, not enough facts and analysis. Yes, some of the responses provided in this thread have been unprofessional. Wifcon Forum is not a reliable source of information. It won't be until the old timers act on their moral responsibility to be more thoughtful in responding to questions than they have done in this thread.

    I have enjoyed meeting people in the Forum, and I have made many friends over the years.

    I wish you all well. All of you. I would not have written this if I didn't. Goodbye and good luck.

  5. The confusion about proposal/offer  is the product of how the concept of "negotiated procurement" developed in government contracting after World War II and the Korean War emergency. I'll describe it one day for a Wifcon article.  There were two factors. First, no one knew what "negotiated procurement" meant in practical terms other than that it was any kind of procurement other than "formal advertising" (now "sealed bidding"). Second, was the concept of "proposal" which emerged from weapon design competitions. It's an interesting story, but too hard for me to write now due to my eye problems.

  6. @LeighHar

    Wait a minute!

    1. What are you pricing? A new subcontract or a subcontract modification?
    2. Does your contract with the government include the clause at FAR 52.215-12 or -13?
    3. If so, is the sub's proposed price greater than the TINA dollar threshold when you signed your government contract?

    What I want to know is whether your government contract requires you to obtain certified cost or pricing data from the sub in this instance. I am unable to determine that from your posts.

    If you want a further response, please answer my three questions.

  7. 46 minutes ago, C Culham said:

    At one time I too was a procurement analyst.  Here you go....

    CO Warrant to $10 million 

    CO awards a purchase ordered valued at $150K to a current Federal employee unknowingly.   Discovered after almost all  work complete. Payment to be made in one payment.   Contractor/individual was performing the work.

    The contract was deemed to be an unauthorized commitment (FAR 1.603-2(a)).

    Agreement was ratified by the head of agency (FAR 3.6).


    No violation of the policy, since the CO did not do so knowingly.  In any case, see FAR 3.602.

  8. See STG International, Inc. v. U.S., COFC Nos. 23-47C; 23-175C, May 24, 2023.

    I have long argued that there is a distinction between offers and proposals. Offers are sets of promises to act or refrain from acting in a specified way, so made as to communicate a willingness to enter into a bargain. Proposals, despite the stupid definition in FAR 2.101, are packages that presumably contain (1) offers and (2) mere information.

    The COFC protest decision demonstrates that fundamental idea in a dramatic way.

    A link to that decision was posted on the home page today.

  9. 14 hours ago, MileHighAcq said:

    so what happens when a contracting officer signs a contract but did not fully comply with a law regarding procedure or contract content? do you not have a legally binding contract?

    See Cibinic and Nash's discussion of Contracts Varying from Statutory or Regulatory Requirements, Unauthorized Variances, in Formation, pp. 72 - 75:


    When unauthorized procedures or terms and conditions are used, a variety of consequences may follow. In some cases, the government may be permitted to avoid the contract. In other instances, the contract may be rewritten to add a mandatory clause or exclude a prohibited clause. Finally, the contractor may be able to require the government to abide by mandatory procedures.

    The most drastic consequence of a contract made in violation of a statute or regulation with the force and effect of law is that the government has the right to avoid the contract. Such contracts have been described as "void ab initio"... "invalid"... or "illegal"...

    When I entered the contracting field, Formation of Government Contracts and Administration of Government Contracts were foundational textbooks. You would see them on the bookshelves of many COs. Not today. Most government offices won't buy it for their trainees, and most government personnel won't spend their own money for it. 

    I will go so far as to say that if you are a contracting "professional" and don't own and read those books, then you are engaged in a battle of wits, and you are unarmed. Invest in your career. Then, get with a few of your colleagues and form a reading and discussion circle.

  10. 45 minutes ago, MileHighAcq said:

    so what happens when a contracting officer signs a contract but did not fully comply with a law regarding procedure or contract content? do you not have a legally binding contract?

    Maybe yes, maybe no. It depends on what law the CO did not comply with.  See Cibinic and Nash.

  11. Ratification applies to authority issues. It does not apply to compliance issues regarding procedure or contract content.

    You cannot ratify a commitment that, had it been made by a contracting officer with requisite authority to make that kind of commitment, would have been illegal because the contracting officer did not comply with a law regarding procedure or contract content.

    It's very, very simple. Read Cibinic and Nash, and think.

    You ratify unauthorized commitments, not improperly made and written commitments. It's just someone who has authority approving after the fact an act of someone who did not.

  12. 2 minutes ago, Jamaal Valentine said:

    While “[n]o contract shall be entered into unless the contracting officer ensures that all requirements of … regulations, and all other applicable procedures, including clearances and approvals, have been met,” I believe Agency Heads and HCAs can deviate from or waive some of these requirements. I believe they may do so through ratifications.

    In Formation, Cibinic and Nash discuss deviations and waivers in pages 69-72.

  13. 1 hour ago, bob7947 said:

    I'm astonished that only formerfed said anything about this procurement.

    Well, it's yet another indication that (1) the Federal Acquisition Streamlining Act of 1994 did not streamline anything, that (2) multi-agency multiple-award IDIQ contracts are a bonanza for the legal profession but are otherwise time-consuming and wasteful, and that (3) the government and political system created by the founders is foundering and nothing can save it from itself. It is proof that we are living in the age of incompetent government.

    There is no chance of meaningful "reform."

  14. 23 hours ago, Sil said:

    The optional CLINs were posted with the RFP, KTRs were asked to propose on those CLINs, those CLINs were evaluated for award, this could have possibly changed the competition? So can we just remove them?

    See Poly-Pacific Technologies, Inc., Comp. Gen. Dec. B-296029, 2005 CPD ¶ 105.

  15. 12 hours ago, Sam101 said:

    To me recording an obligation means obligating funds in a computer...

    @Sam101 Who, besides you, cares what it means to you?

    See 31 USC § 1501, Documentary evidence requirement for Government obligations

    (a) An amount shall be recorded as an obligation of the United States Government only when supported by documentary evidence of—
    (1) a binding agreement between an agency and another person (including an agency) that is—
    (A) in writing, in a way and form, and for a purpose authorized by law; and
    (B) executed before the end of the period of availability for obligation of the appropriation or fund used for specific goods to be delivered, real property to be bought or leased, or work or service to be provided;
    (2) a loan agreement showing the amount and terms of repayment;
    (3) an order required by law to be placed with an agency;
    (4) an order issued under a law authorizing purchases without advertising—
    (A) when necessary because of a public exigency;
    (B) for perishable subsistence supplies; or
    (C) within specific monetary limits;
    (5) a grant or subsidy payable—
    (A) from appropriations made for payment of, or contributions to, amounts required to be paid in specific amounts fixed by law or under formulas prescribed by law;
    (B) under an agreement authorized by law; or
    (C) under plans approved consistent with and authorized by law;
    (6) a liability that may result from pending litigation;
    (7) employment or services of persons or expenses of travel under law;
    (8) services provided by public utilities; or
    (9) other legal liability of the Government against an available appropriation or fund.
    (b) A statement of obligations provided to Congress or a committee of Congress by an agency shall include only those amounts that are obligations consistent with subsection (a) of this section.
    Now go do some reading.
  16. 2 hours ago, Sam101 said:

    Yes, the OF347 not having a block for the vendor countersignature is what is causing me to obligate funds without knowing if the contractor will even accept the order.

    41 minutes ago, Sam101 said:

    Because even if the contractor does not provide written acceptance they can still begin performing, right? So how can they begin performing if there are no funds obligated?



    See Principles of Federal Appropriations Law (GAO Read Book), Vol. II, Ch. 7, Obligation of Appropriations, pp. 7-12 to 7-13:


    A mere request for additional supplies under a purchase order with no indication of acceptance of the request does not create a recordable obligation. 39 Comp. Gen. 829 (1960). Similarly, a work order or purchase order may be recorded as an obligation only where it constitutes a binding agreement for specific work or services. 34 Comp. Gen. 459 (1955)..

    Now, I know that quote will prompt some questions. That's why I posted it. But don't ask them. If you do, I won't answer them.

    Get off Wifcon and, for answers, hit the books.

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