Overview
FAR 4.803 provides a comprehensive list of the records that normally constitute a complete contract file, categorized by the specific responsibilities of the contracting, administration, and paying offices. It serves as the standard for documenting the entire acquisition lifecycle, ensuring a clear audit trail from initial planning through final payment and closeout.
Key Rules
- Tripartite Filing System: The regulation distinguishes between the records required for the Contracting Office (pre-award and award focus), the Contract Administration Office (performance and oversight focus), and the Paying Office (financial focus).
- Documentation of Competition and Selection: Files must include evidence of market research, justifications for set-asides, lists of sources solicited, and detailed records of the source selection process.
- Retention of Unsuccessful Offers: While unsuccessful offers can be stored separately, specific portions—including technical proposals, cost/price proposals, and any altered solicitation pages—must be retained and cross-referenced.
- Price Reasonableness and Negotiation: Contracting officers must document the basis for determining a fair and reasonable price, including cost or pricing data, audit reports, and the formal Record of Negotiation.
- Administrative History: The file must contain a chronological list of all awarding and successor contracting officers to maintain accountability throughout the life of the contract.
- Legal and Statutory Compliance: Mandatory inclusions include justifications and approvals (J&As) for non-competitive actions, evidence of legal review, and records of compliance with labor and small business policies.
Practical Implications
- Audit Readiness: This section acts as a mandatory checklist for Contracting Officers to ensure their files are "protest-proof" and can withstand scrutiny from the GAO, Agency Protests, or the Office of Inspector General (OIG).
- Continuity of Operations: By requiring a standardized and chronological record, the regulation ensures that successor contracting officers can manage or modify a contract with a full understanding of the original intent and prior administrative actions.