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    Where in all of the FARs, OPM, NARA policies can I locate the ploicy stating just how long after award are hardcopy contract file folders to be created.


    Answer

      I didn’t understand your question at first because I was unable to believe that your contracting officers do not look at a file documentation before making contract award.  As you stated in our phone conversation, contract awards are made in your organization and then the file documentation is completed months later.  I do not think this is an acceptable process and I applaud you for trying to change the way your procurement agency is doing business.  In order to answer your question, I reviewed FAR Part 4, Administrative Matters and all supplements, including the military services and various civilian agencies.  I found no supplements that addressed the timing of the file documentation.  I did find several good checklists that might be helpful. 

    I’ve included the Air Force checklist at https://acc.dau.mil/CommunityBrowser.aspx?id=722368 and this is a link to the checklists used at the Defense Information Security Agency, https://www.ditco.disa.mil/DitcoContractingTemplates/doku.php?id=contract_file_checklists  I think the problem in your organization is that your contracting officers have been taught to sign contracts without reviewing all the documentation that is needed to make a contract award.  Obviously this would be dependent upon the thinking of the warranting authority, but I believe your contracting officers are risking the loss of their warrant.  Please look at FAR 1.602-1 (b), which addresses the authority given by the warrant.  If the contracting officers are not reviewing the items found in the contract file, such as the evidence of the availability of funds/source selection documentation/data supporting a fair and reasonable price/justifications for sole source or types of contract/evidence of legal review/required synopses/etc., then they are not doing their job, could easily be breaking a law and should lose their warrants until they are retrained.  This is obviously an organizational culture issue and I think it is very risky. 

    FAR 1.602-1, Authority
    (a) Contracting officers have authority to enter into, administer, or terminate contracts and make related determinations and findings. Contracting officers may bind the Government only to the extent of the authority delegated to them. Contracting officers shall receive from the appointing authority (see 1.603-1) clear instructions in writing regarding the limits of their authority. Information on the limits of the contracting officers’ authority shall be readily available to the public and agency personnel.
    (b) No contract shall be entered into unless the contracting officer ensures that all requirements of law, executive orders, regulations, and all other applicable procedures, including clearances and approvals, have been met.

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