Yesterday in Part 1 of this series, we discussed the various tasks that the ACO (Administrative Contracting Officer) must complete before they can be considered "administratively complete". There are a lot of them. Today, we look at one of the tasks that contractors must perform in order to close out a contract - the "completion voucher".
Contractors must submit a completion voucher within 120 days after settlement of the final annual indirect costs rates for all years of the physically complete contract. So, for example, if a contract runs for three years - 2013, 2014, and 2015 - the contractor would submit its completion voucher when the rates for 2015 are settled.
A contractor can take more than 120 days to submit completion vouchers. The ACO (Administrative Contracting Officer) can approve an exception to the 120 day rule based on a written request citing exceptional circumstances. Usually, such approval is perfunctory and granted without good reasons on the contractors part but we have seen recent cases where the pressure to close old contracts makes such approval not so assured.
Final voucher are submitted via iRAPT (Invoicing, Receipt, Acceptance, and Property Transfer System). Formerly iRAPT was known as WAWF, a name still used and more recognizable to contractors.
We should note that if a contractor fails to submit a completion invoice or voucher within the time specified, the administrative contracting officer may determine the amounts due to the contractor under the contract and record the determination in a unilateral modification to the contract. We have seen unilateral modifications in cases where a contractor has gone out of business or has lost accounting records.
What happens after contractors submit completion vouchers depends upon the adequacy of existing records.
DCAA would like everyone to believe that the Schedule I - Schedule of Cumulative Direct and Indirect Costs Claimed and Billed - of contractors' annual incurred cost submissions is the only tool necessary to validate costs. We will discuss some of the pitfalls associated with relying on Incurred cost submissions tomorrow.