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  • Question

    If all three clauses in a cost reimbursement type contract are identified (either in section E or by reference), then why is a voucher being used to identify the completion of a delivery when the submission of a receiving report by the contractor and validated by a COR/QA utilizing corresponding source documents not being used, scrutinized and taught? Keep in mind that the voucher is subject to audit and approved by DCAA for invoice payment by DFAS. A COR or other authorized person who is authorized to see the voucher cannot verify delivery, only that the contractor correctly billed for the respective delivery IAW the contract.

    Answer

    The short answer is that vouchers are used because the allowable cost and payment clause at FAR 52.216-7 is prescribed for cost reimbursement contracts.  DCAA has sole authority on interim payments (vouchers) and even the completion voucher that gets sent to the ACO is subject to an audit by DCAA.
     
    That being said, you are correct that DFARS 252.246-7000 requires the contractor to submit an inspection and receiving report "in the manner and to the extent required by DFARS Appendix F".  Although a quick review of the items in appendix F does indicate a very limited application for service contracts.  The electronic receiving form to be submitted in WAWF (iRAPT) should be specified within the clause at DFARS 252.232-7006, but that detail can also be managed by choosing the "document type" (say a 2n1) to be created within the system.  Either way paragraph f(4) of that clause requires the contractor to include applicable information from DFARS Appendix F on any payment request.  So, it is possible for contractors to be in compliance with DFARS 252.246-7000 without using an official receiving report as long as any necessary information is conveyed on their payment request.
     
    An explanation as to why you wouldn't have a receiving report associated with interim payments is a cleaner discussion.  FAR 32 defines interim payments under a cost-reimbursement contract for services as invoice payments when alternate I is used with FAR 52.232-25.  FAR 32.905(c) then provides an exception for cost-reimbursement service contracts by stating, "All invoice payments, with the exception of interim payments on cost-reimbursement contracts for services, must be supported by a receiving report or any other Government documentation authorizing payment."

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