Is there any violation of policies or guidelines when another COR receipts, and accepts invoices on behave of another COR? If there is a violation, PFPA would like to remediate and document the issue so it will not become a financial audit finding in the future.
This is a good question. It is a variation of a question I have answered many times here at Ask-A-Professor and the last time was just 3 ½ weeks ago! However, it was not filed in the COR folder (sorry). Here’s a link to it.
In your particular situation I would not be too concerned. The ultimate issue we are really concerned about is that the government received what we wanted and the contractor got paid in time. I’ve mentioned in the past that we sometimes get wrapped around the axel on “business process rules” rather than the rules of the federal acquisition regulations (which are often flexible for important reasons).
Your issue is a classic example. If the COR who was having trouble accessing WAWF/iRAPT was the one who verified the contractor accomplished/delivered what they were supposed to (i.e. contractor’s work and deliverables conformed to contract requirements: quantity, quality, schedule, etc.), you are probably ok. In other words the right COR ensured inspection was accomplished and determined the government was authorized to “accept” and therefore pay the contractor. So long as that COR somehow documented this either in their COR file or via an e-mail they sent to the “other COR” who had no issues with WAWF/iRAPT.
Now, if the COR basically said to the other COR “hey, I don’t have access to WAWF/iRAPT, will you do my inspection and acceptance for me?” Then we would have a problem. The problem is that the COR is not authorized to delegate to their responsibilities (e.g. inspection and acceptance) to anyone else. You see, pushing the button in iRAPT is basically just the government saying we have done proper inspection and acceptance.
As I said in the question answer linked above:
Many organizations and installations in DoD have a select number of people go into WAWF and complete the transaction to authorize payment to the contract. This makes sense from an efficiency and division of labor standpoint. Rather than have tens, hundreds, or even thousands of CORs on an installation be WAWF trained and certified is not always the best use of time.
So, for the SOP you are developing; you could include something along the lines of: If the COR is having issues with a WAWF application and it cannot be resolved prior to contractor payment requirements, the COR should document their file with the results of the inspection and declaratively state it is the COR’s or Governments intention to “accept” the contractor’s work and authorize payment.
That way you know the FAR/DFARS rules have been followed.
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