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  • Question

    Are COE contracts exempt from requiring contractors to use WAWFsystem? Does COE use a different system? Thank you.


    Answer

    1. We assume the term “COE” means the U.S. Army Corps of Engineers. Also, the DFARS references quoted below in pertinent part are applicable to this response.

    DFARS 201.402 – Policy.
    (1) The Director of Defense Procurement and Acquisition Policy, Office of the Under Secretary of Defense (Acquisition, Technology, and Logistics) (OUSD(AT&L)DPAP), is the approval authority within DoD for any individual or class deviation from—
      (vi) FAR Part 32, Contract Financing (except Subparts 32.7 and 32.8 and the payment clauses prescribed by Subpart 32.1), or DFARS Part 232, Contract Financing (except Subparts 232.7 and 232.8).

    DFARS Subpart 232.70 — Electronic Submission and Processing of Payment Requests and Receiving Reports
    DFARS 232.7002 – Policy
    (a) Contractors shall submit payment requests and receiving reports in electronic form, except for—
      (1) Purchases paid for with a Governmentwide commercial purchase card;
      (2) Awards made to foreign vendors for work performed outside the United States;
      (3) Classified contracts or purchases when electronic submission and processing of payment requests could compromise the safeguarding of classified information or national security;
      (4) Contracts awarded by deployed contracting officers in the course of military operations, including, but not limited to, contingency operations as defined in 10 U.S.C.101(a)(13) or humanitarian or peacekeeping operations as defined in 10 U.S.C. 2302(8), or contracts awarded by Contracting Officers in the conduct of emergency operations, such as responses to natural disasters or national or civil emergencies;
      (5) Purchases to support unusual or compelling needs of the type described in FAR 6.302-2;
      (6) Cases in which DoD is unable to receive payment requests or provide acceptance in electronic form; or
      (7) Cases in which the Contracting Officer administering the contract for payment has determined, in writing, that electronic submission would be unduly burdensome to the contractor.

    DFARS 232.7003 – Procedures.
    (a) The accepted electronic form for submission of payment requests and receiving reports is Wide Area WorkFlow (see website – https://wawf.eb.mil/ ).

    (b) If the payment office and the contract administration office concur, the Contracting Officer may authorize a contractor to submit a payment request and receiving report using an electronic form other than Wide Area WorkFlow. However, with this authorization, the contractor and the Contracting Officer shall agree to a plan, which shall include a timeline, specifying when the contractor will transfer to Wide Area WorkFlow.

    (c) For payment of commercial transportation services provided under a Government rate tender or a contract for transportation services, the use of a DoD-approved electronic third party payment system or other exempted vendor payment/invoicing system (e.g., PowerTrack, Transportation Financial Management System, and Cargo and Billing System) is permitted.

    DFARS 232.7004 – Contract clause
    Except as provided in 232.7002(a), use the clause at 252.232-7003, Electronic Submission of Payment Requests and Receiving Reports, in solicitations and contracts.

    2. Pursuant to the DFARS requirements described above, submittal of paper invoices by the contractor is not permitted, and the submittal of electronic invoices is required, unless the contracting activity has obtained a formal deviation to DFARS Subpart 232.70 approved by the Director of Defense Procurement in accordance DFARS 201.402(1)(iv) or unless one of the exceptions set forth in DFARS 232.7002(a) is applicable to the contracting action. Furthermore, as specified in DFARS 232.7003(a), electronic invoices must be submitted using WAWF unless the conditions described in DFARS 232.7003(b) or (c) apply.  Additionally, pursuant to DFARS 232.7004, the clause at DFARS 252.232-7003 must be used in all solicitations and contracts unless the exceptions noted above apply.
     
    3. Consequently, except as noted above, we do not believe that COE contracts are exempt from requiring contractors to use WAWF system.  In addition, our search of the Army Federal Acquisition Regulation Supplement (AFARS) and the Engineer Federal Acquisition Regulation Supplement (EFARS) [applicable to the U.S. Army Corps of Engineers] did not disclose the existence of any other approved payment system for use by the U.S. Army Corp of Engineers.


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