Overview
FAR 4.801 mandates that contracting, administration, and paying offices establish and maintain comprehensive records of all contractual actions to ensure a complete and transparent history of every transaction.
Key Rules
- Mandatory File Creation: The heads of offices involved in contracting, administration, or payment must establish files for all contractual actions.
- Sufficiency Standard: Documentation must be detailed enough to provide a complete background for informed decision-making, support all actions taken, and facilitate reviews, investigations, litigation, or congressional inquiries.
- Required File Categories:
- Cancelled Solicitations: Records regarding acquisitions that did not result in an award.
- Individual Contract Files: Dedicated records for each specific contract.
- Contractor General Files: Records containing non-contract-specific data, such as management systems, past performance reports, and general capabilities.
Practical Implications
- Audit Readiness: This section reinforces the "if it isn't in the file, it didn't happen" principle, requiring Contracting Officers to document every significant decision to survive legal and administrative scrutiny.
- Administrative Burden: Agencies must maintain rigorous organizational standards to ensure that cross-contract documentation (like past performance) is accessible and consistently applied during future evaluations.