Do you keep a contract file 6 yrs 3 mos after final payment - or does de-obligation of excess funds count as final payment?
More specifically, if you have a FFP contract do you retain the contract file from the date of final payment of the delivered supplies/services, or from the date in which a de-obligation of excess funds was signed, assuming the de-obligation was after the POP and final payment date?
In accordance with FAR 4.804-5 (a)(14),(15) Procedures for close out of contract files says "The contract administration office is responsible for initiating administrative closeout of the contract after receiving evidence of its physical completion. At the outset of this process.............of any excess funds the contracting office might deobligate. When complete the administrative closeout procedures must ensure that....(14) Contractor's final invoice has been submitted: and (15) Contract funds review is completed and excess funds deobligated". Based on this, the time begins toward the 6 yrs 3 mos after both the final payment has been submitted and any excess funds have been deobligated.
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