If we do this administrative modification should we make it bilateral? Would we require releases as we would in a final voucher package? What other things do we need if we want to administratively closeout a contract where there is little to no documentation?
You indicate that you have almost no information regarding this contract which has been physically complete for 14 years; that DCMA, the contractor, nor DCAA has any information to support final rates. You also state that your legal office has reviewed your proposed resolution of the issue and presumably did not disagree with it, but wanted you to obtain a higher level of review. Given this summary, and no evidence of a final voucher from the contractor for the remaining funds on the contract, your proposed action appears sound.
Open full Question Details
I recommend that your final modification to deobligate the remaining funds be bilateral to ensure that the contractor is in agreement with the action taken by including a release of further claims per FAR 43.204(c)(2) with appropriate wording changes. I would also recommend you fully document your contract file to support the actions taken to close the contract (see DD Forms 1594 and 1597).