MAIL BAG: WHAT’S IN YOUR CONTRACT FILE SHOULDN’T BE A MYSTERY
Alert reader F. Mulder writes in asking, “I am at least the third contract manager our company has had over the 15 years of our GSA Schedule. I can’t find documentation for the agreements we made 10 years ago, or even more recently. How much of a problem could this be?” Your situation is not alien to us, F. Many companies have had multiple Schedule contract managers, and multiple GSA contracting officers. Files on both sides are liable to be incomplete and, those that can be found, confusing. This, unfortunately, does not mean you’re off the hook for missing documentation. Auditors expect complete contract files and view missing documents with suspicion. More than one company has paid large False Claims Act fines at least in part because the terms that “everyone knew” had been agreed upon could not be found in writing. Some ways to restore missing documents include searching in other divisions inside your company. Those divisions may have a record of what they told your predecessor on pricing and discount policies. Your IT department may be able to restore old e-mails. If all else fails, some companies have been known to FOIA their own contract files from GSA. While these methods can be time consuming and expensive, they pale in cost to negative audit findings. The truth is out there.