B-161635, JUL 25, 1972, COMPTROLLER GENERAL OF THE UNITED STATES

B-161635: Jul 25, 1972

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SECRETARY: REFERENCE IS MADE TO YOUR LETTER DATED JANUARY 18. THE REQUIREMENT THAT ALL CONTRACTS BE SENT TO THE MILITARY FINANCE CENTERS FOR USE IN CONNECTION WITH THE AUDIT AND SETTLEMENT OF DISBURSING OFFICERS' ACCOUNTS WAS COVERED IN A LETTER DATED MARCH 15. ON OF THE PROPOSALS MADE BY DOD IN 1966 WAS THAT CONTRACTS ADMINISTERED AND PAID BY THE DEFENSE CONTRACT ADMINISTRATIVE SERVICES REGIONS (DCASRS) WOULD NO LONGER BE SENT TO THE MILITARY FINANCE CENTERS BUT WOULD BE FILED AT THE DCASRS FOR ON-SITE GAO REVIEW. AT THE TIME THESE LETTERS WERE WRITTEN. THE DEFENSE SUPPLY AGENCY WAS CONSIDERING A PROPOSAL TO CREATE A CENTRAL INDEX OF ALL DEFENSE CONTRACTS BUT THE IDEA WAS ABANDONED IN 1966.

B-161635, JUL 25, 1972, COMPTROLLER GENERAL OF THE UNITED STATES

PRECIS-UNAVAILABLE

DEAR MR. SECRETARY:

REFERENCE IS MADE TO YOUR LETTER DATED JANUARY 18, 1972, WITH ENCLOSURES, REQUESTING OUR COMMENTS AND SUGGESTIONS CONCERNING THE ASSISTANT SECRETARY OF THE ARMY (I&L) MEMORANDUM OF JANUARY 11, 1972, WHICH SUGGESTS THE ELIMINATION OF THE REQUIREMENT (ASPR 20-402) TO FORWARD ORIGINAL SIGNED COPIES OF CONTRACTS AND MODIFICATIONS EXCEEDING $2,500 TO DEPARTMENTAL FINANCE CENTERS FOR REVIEW BY OUR OFFICE AND SUBSEQUENT STORAGE FOR POSSIBLE FUTURE USE.

THE REQUIREMENT THAT ALL CONTRACTS BE SENT TO THE MILITARY FINANCE CENTERS FOR USE IN CONNECTION WITH THE AUDIT AND SETTLEMENT OF DISBURSING OFFICERS' ACCOUNTS WAS COVERED IN A LETTER DATED MARCH 15, 1962, B-147752, FROM THE COMPTROLLER GENERAL TO THE SECRETARY OF DEFENSE.

IN CONNECTION WITH THE FORMALIZING OF THE MILITARY STANDARD CONTRACT ADMINISTRATION PROCEDURES (MILSCAP), MEMBERS OF OUR STAFF HAD NUMEROUS MEETINGS AND EXCHANGES OF CORRESPONDENCE WITH DEPARTMENT OF DEFENSE (DOD) OFFICIALS SINCE 1965. ON OF THE PROPOSALS MADE BY DOD IN 1966 WAS THAT CONTRACTS ADMINISTERED AND PAID BY THE DEFENSE CONTRACT ADMINISTRATIVE SERVICES REGIONS (DCASRS) WOULD NO LONGER BE SENT TO THE MILITARY FINANCE CENTERS BUT WOULD BE FILED AT THE DCASRS FOR ON-SITE GAO REVIEW. LETTERS OF JULY 19 AND AUGUST 22, 1966, THE ASSOCIATE DIRECTOR OF OUR THEN DEFENSE ACCOUNTING AND AUDIT DIVISION ADVISED THAT OUR APPROVAL OF THE RELOCATION OF CONTRACTS WOULD DEPEND ON THE DEVELOPMENT OF AN EFFECTIVE METHOD OF CONTINUING CENTRAL IDENTIFICATION AND RESEARCH OF DEFENSE CONTRACTS. AT THE TIME THESE LETTERS WERE WRITTEN, THE DEFENSE SUPPLY AGENCY WAS CONSIDERING A PROPOSAL TO CREATE A CENTRAL INDEX OF ALL DEFENSE CONTRACTS BUT THE IDEA WAS ABANDONED IN 1966. WE WERE NOT ADVISE UNTIL 1969 THAT DOD HAD DECIDED TO CONTINUE THE PRACTICE OF SENDING THE GAO COPY OF DCASR ADMINISTERED CONTRACTS TO THE MILITARY FINANCE CENTERS.

AS WE HAVE HERETOFORE INDICATED, WE WOULD NOT OBJECT TO THE RETENTION OF CONTRACT FILES BY THE SERVICES AND THE DEPARTMENT OF DEFENSE AT OTHER THAN THE FINANCE CENTERS PROVIDED A MUTUALLY ACCEPTABLE METHOD IS DEVELOPED FOR OUR IDENTIFICATION AND RESEARCH PURPOSES. FOR EXAMPLE, IT MIGHT BE NECESSARY FOR US TO REQUEST THE IDENTIFICATION OF THE CONTRACT ITEMS AND NUMBERS OF ALL CONTRACTS ISSUED TO A CERTAIN CONTRACTOR FOR A GIVEN PERIOD. IN ADDITION, THE CONTRACTS WOULD HAVE TO BE FURNISHED THE GENERAL ACCOUNTING OFFICE ON REQUEST FOR USE WHEN AND WHERE REQUIRED IN CONNECTION WITH THE AUDIT AND SETTLEMENT OF DISBURSING OFFICERS' ACCOUNTS, OUR CLAIMS SETTLEMENT MATTERS AND FOR OTHER PURPOSES, AS NEEDED. IN THIS CONNECTION, IT SHOULD BE NOTED THAT THERE IS A TEN-YEAR STATUTE OF LIMITATIONS APPLICABLE TO CLAIMS BEFORE OUR OFFICE. BECAUSE OF THIS STATUTE THE RECORDS SHOULD BE KEPT AVAILABLE FOR NOT LESS THAN 10 YEARS AND 3 MONTHS. ANY CHANGE IN PRESENT PROCEDURES SHOULD BE UNIFORMLY IMPOSED ON ALL THE SERVICES AND THE DEFENSE AGENCIES MAKING UP THE DEPARTMENT OF DEFENSE. COURSE, THE PLACE OF STORAGE OF THE RECORDS, AS INDICATED, IS NOT MATERIAL PROVIDED THEY ARE READILY ACCESSIBLE WHEN NEEDED AND A CURRENT LOCATOR SYSTEM IS MAINTAINED BY CONTRACTOR, CONTRACT NUMBER AND SUBJECT MATTER.

THE HONORABLE: THE SECRETARY OF DEFENSE.