(a) Contractual instruments shall be developed within the contract writing system. This policy may be enforced through audits and inspections at the discretion of AFMC/PK. This policy applies to all contractual instruments executed at each Center / AFRL using the respective local system- Standard Procurement System (SPS), ConWrite or Automated Contract Writing Preparation System (ACPS). The policy is more specifically delineated as follows:
(1) Contract Writing Capabilities: All pre-award activity and post-award modifications and orders must be accomplished exclusively within the contract writing systems. No changes are to be made outside of the contract writing systems. Accordingly, ConWrite and ACPS shall be set to a default that prevents opening the contract in Microsoft WORD prior to contract award to preserve original data integrity. SPS users shall use the Integrity Tool to assure accuracy of data prior to release of awards. Changes shall not be made outside of the SPS system (e.g., Microsoft WORD document changes and/or pen & ink changes). “Face Page Awards” are not permitted. (“Face Page Awards” refer to using the system to generate the face page only with other contract Sections B through J data not being input within the contract writing system as required). All contract documents shall be electronically distributed, in their entirety, exclusively within and through the contract writing systems, unless an exemption and/or waiver has been granted. Requests for exemptions and/or waivers may be granted on a case-by-case basis by the Senior Center Contracting Official (SCCO). Requests for class exemptions and/or waivers may be granted by the Senior Contracting Official (SCO), AFMC/PK. Three AFMC/PK SCO class exemptions have been granted as follows:
a. Exemption No. 1: DD Form 1423, CDRLs, Class Waiver: CDRLs may be identified on a priced or not separately priced CLIN and a separate Exhibit Identifier, as appropriate, with the DD Form 1423s included as Exhibits within Section J of the contract.
b. Exemption No. 2: List of Spares/Reparable Items as Section J Attachment: The current practice of including a Microsoft Word document and/or Excel spreadsheet for a “List of Spares/Reparable Items” within Section J of a Basic IDIQ contract or BOA is acceptable, provided the Contract Line Item Number or Exhibit Line Item(s) is established and captured as data within the contract writing system when the part or repair is ordered against the contract and all National Stock Numbers (NSNs) on that list are entered into the Compliance Database. The Compliance Database is a tool that contains a list of all NSNs that have been placed on a corporate or strategic sourcing contract. The database is populated by the Commodity Councils and maintained by HQ AFMC/PKT. The mandatory use of Commodity Council contracts is directed by HQ AFMC/LG Policy Letter “Mandatory Coordination with Commodity Council Directors on New Purchase Requests (PR) for Multiple Year Contracts and Mandatory Use of Commodity Council Contracts” dated 11 Jul 2005.
c. Exemption No. 3: PIO Class Waiver: Initial Provisioning Spares ordered through the D220 Provisioning Computer System, which produces the Provisioned Item Order (PIO), are exempt from this policy. The PIO contains all the necessary information required to procure a spares item and the data is captured in the same manner as ACPS. The data created in D220 is sent to contracting via AFMC Form 778 and flows from D220 to J018, J041 and D043. The data is then brought into the Contracting Business Intelligence System (CBIS) where it is available for analysis.
d. Specific Waivers: Previously approved specific waivers remain in effect. Specific waivers are granted to apply to a specific contracting situation with more than one contract action, or for a limited time as defined in the approved waiver. A copy of the approved specific waiver shall be included in the official contract file when the waiver has been applied. This will assist any reviewers or auditors in clearly understanding that the contracting officer intended for the waiver to apply to that specific contract action.
(2) Waiver Process: The SCCO may approve a waiver for an individual contract action that allows for a specific transaction to be awarded without all the data being entered within the contract writing system. AFMC/PK may approve a waiver for a class of contract actions that allows for a specific class of transactions to be awarded without all the data being entered within the contract writing system. All SCCO approved waivers shall be copied to AFMC/PKXB with the justification, including an identification of where the data originates so that we may identify where system interfaces need to be developed or modified. All requests for class waivers should be addressed to AFMC/PKXB with justification, including an identification of where the data originates and endorsement by the Center Director of Contracting. The original waiver or a copy, in the case of a class waiver, shall be retained in the official contract file for each contract action accomplished under the waiver.
(3) Contracting Data Integrity: Capturing complete and accurate data is critical to support efforts at institutionalizing improved processes such as strategic sourcing, commodity councils, and electronic data interchange (EDI) between suppliers and DoD partners. The future of contracting across the DoD, including future migrations to next generation contracting tools, will increasingly rely on electronically capturing accurate and complete contracting data. Thus, proper use of the current contract preparation tools, e.g. ConWrite, ACPS and SPS, is critical and the responsibility of every member of the contracting community. Proper use necessitates not only working within the contracting preparation tool, but also being personally responsible to insure all relevant data is accurate and appropriately collected within the systems.
(4) Contracting Data Repositories: Data Base Administrators (DBAs), or equivalent personnel with access to data base capabilities, shall not modify data in a data base to correct mistakes on contract documents. All post award corrections or modifications to correct erroneous data caused by mistakes or errors shall be made through a contract writing system. The correcting transaction shall take the form of a contract modification that is released to all parties in the same manner as the contracting transaction containing the erroneous data. Information Assurance and Chief Financial Officer compliance require that all changes/corrections to contracting databases provide an audit trail to clearly show when an item was changed and who changed it. Manual database corrections should be done only when the error was system software induced, not being the fault of the system user. DBAs are considered to be "Trusted Agents" and are authorized (with appropriate local PK approval) to make necessary manual changes to the contract writing system database for the express purpose of correcting those errors caused by the contract writing system software. All such errors, and the database changes made, shall be documented in a log (an audit trail) and reported to AFMC/PKXB and the appropriate office responsible for the software maintenance of that contract writing system. (NOTE: When the database software provides an internal audit trail with the capability to capture DBA comments, the internal log may be used in lieu of a manual log. However, notification still must be made to the appropriate office responsible for the software maintenance of that contract writing system as well as to AFMC/PKXB.)
(5) Audits/Inspections: At the discretion of HQ AFMC/PK, this policy may be enforced through audits and inspections, including review of the official contract files and database queries, to assure there is appropriate documentation for authorization of changes made outside of the contract writing systems, as applicable (e.g., ACPS, ConWrite or SPS). Database Administrator’s logs/audit trails are also subject to audits and inspections to assure that Information Assurance and CFO compliance are being met.
