My questions are as follows:
a) Is there any guidance that supersedes PGI 204.804-1(1) that would preclude a contracting organization from uploading the completed DD Form 1594 or local equivalent into EDA.
b) What is the impact of not having the DD 1594 or local equivalent in EDA?
I spoke to the subject matter expert at the Defense Procurement and Acquisition Policy office. He advised that the absence of a record of closeout in EDA for a contract on which final payment has been made can be attributed to several possible factors:
1. The contract is not closed because of the need to perform administrative steps beyond final payment. Examples include: dispositioning patent rights and transferring government furnished property.
2. The contract is not eligible for automated closeout and the closeout process has not been performed manually.
3. Notice of closeout has not been sent to EDA. This could be because the contract closeout predated the requirement to send that information to EDA, or because the office performing the closeout has not deployed a capability for sending the transactions. DPAP is continuing to work with the Components to identify closeout records that have not been transmitted and to ensure those are distributed.
I have also contacted the Air Force Policy office. I have not received an official response, but I do have a point of contact who is researching your question. You may want to contact her at Sheila.firstname.lastname@example.org . I also spoke to an Army representative who said that the modifications of contract writing systems to be able to send the transactions to EDA is still being worked.The Army is currently working towards building capability into the contract writing system, PD2, that will send the 1594 to EDA and will be piloting the functionality in the near future. Based on this information, the 3rd explanation above may be the primary reason why you are not seeing the closeout record in EDA. In those cases, the 1594 should be found in the contract file. There is no impact, except lack of transparency.
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