![](media/image1.wmf){width="1.4013888888888888in"
height="1.2680555555555555in"}***NATIONAL AERONAUTICS AND***

***SPACE ADMINISTRATION***

**GSFC Procurement**

**Self-Assessment Survey Report**

GODDARD SPACE FLIGHT

CENTER

**October 30, 2006**

# 

# Table of Contents

# 

[Table of Contents 2](#table-of-contents)

[Introduction 3](#introduction)

[Methodology 3](#methodology)

[Review Team 3](#review-team)

[Scope of Review 4](#scope-of-review)

[EVALUATION OF PERFORMANCE (NF 1680)
5](#evaluation-of-performance-nf-1680)

[**Recommendations (Evaluation of Performance (NF 1680))**
6](#recommendations-evaluation-of-performance-nf-1680)

[COST PLUS AWARD FEE (CPAF) CONTRACTS
7](#cost-plus-award-fee-cpaf-contracts)

[**Findings** 7](#findings-cpaf-contracts)

[**Recommendations** 7](#recommendations-cpaf-contracts)

[INTERAGENCY ACQUISITIONS (IA's) 8](#interagency-acquisitions-ias)

[**Findings**
8](#findings-ia-compliance-with-far-17.504-c-and-gsfc-pic-99-3)

[**Recommendations**
8](#recommendations-ia-compliance-with-far-17.504-c-and-gsfc-pic-99-3)

[CONSTRUCTION CONTRACTS 9](#construction-contracts)

[**Findings** 9](#findings-construction-contracts)

[**Recommendations** 10](#recommendations-construction-contracts)

[A&E Contracts 11](#a-e-contracts)

[**Findings** 11](#findings-ae-contracts)

[**Recommendations** 11](#recommendations-ae-contracts)

[ATTACHMENTS TO THE SELF-ASSESSMENT REPORT
12](#attachment-a--overall-assessment-and-recommendations)

[Attachment A\--Overall Assessment And Recommendations
13](#attachment-a--overall-assessment-and-recommendations)

[Attachment
B](#attachment-a--overall-assessment-and-recommendations)---Checklist
for The Contractor\'s Request For Progress Payments In Accordance with
FAR 52.232
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# Introduction

The Goddard Space Flight Center (GSFC) conducted a functional
self-assessment survey of the procurement function at the GSFC, which
includes the Headquarters (HQ) procurement branch and the Wallops Flight
Facility (WFF). This survey was conducted using the procedures outlined
in NASA's Self-Assessment Guide and the directions included in the
Associate Administrator for Procurement memoranda of September 30, 1998
and February 18, 2000.

This report contains a summary of the findings and recommendations to
improve deficiencies noted. All actions surveyed were identified in the
last NASA HQ Procurement Management Survey Report as having weaknesses.
This report will be retained as a quality record under the ISO process,
as required.

# Methodology

This self-assessment focused on specific areas of weakness identified in
the most recent NASA HQ Procurement Management Survey Report which
covered the period of August 15 through August 26, 2005. In addition,
this self-assessment focused on regimented corrective action for
selected areas whereby weaknesses were identified. Random compliance
reviews of a representative sample of procurement actions that were
identified as having weaknesses in the NASA HQ Procurement Management
Survey Report were conducted for actions awarded or completed during
fiscal year 2006. The review focused on completion of Evaluation of
Performance Forms (NF 1680), Cost Plus Award Fee (CPAF) Contracts,
Interagency Agreements, Construction Contracts and Architect and
Engineering (A&E) Contracts and their compliance with Federal
Acquisition Regulation (FAR), NASA FAR Supplement (NFS), and local
guidance. In accordance with the guidance provided in the NASA
Self-Assessment Guide, we reviewed at least five percent of each of
these actions.

The report addresses those areas where inconsistencies or non
compliances were found. For the most part, all of the files were neatly
filed and maintained, and except as noted in this report, contained all
of the required, compliant documentation.

# Review Team

The following individuals participated as members of the self-assessment
review team:

  ------------------------------------------- ---------------------------
  **Name (Code)**                             **Functional Area
                                              Reviewed**

  Camille Thurston (210.I), Chris Whyte       Evaluation of Performance
  (210), and Candace Carlson (210)            (NF 1680) (Greenbelt,
                                              Wallops and Headquarters)

  Camille Thurston (210.I), Cindy Stoltz      Cost Plus Award Fee
  (210)                                       Contracts (Greenbelt)

  Camille Thurston (210.I), PSST (210)        Interagency Agreements
                                              (Greenbelt)

  Camille Thurston (210.I)                    Construction Contracts
                                              (Greenbelt and Wallops)

  Camille Thurston (210.I)                    Architect and Engineering
                                              Contracts (Greenbelt)
  ------------------------------------------- ---------------------------

# Scope of Review

The SAP database was the primary system used to select the random sample
pool. Using the recommended review percentages as a minimum, the
following numbers of procurement actions were selected for this review:

+---------------------------------------+----------------+------------+
| **Type of**                           | **Total        | **Number** |
|                                       | Number**       |            |
| **Procurement**                       |                | **         |
|                                       | **Of Actions** | Reviewed** |
+---------------------------------------+----------------+------------+
| Evaluation of Performance (NF1680)    | 23             | 10         |
| (period ending 7/2006)                |                |            |
+---------------------------------------+----------------+------------+
| Cost Plus Award Fee (CPAF) Contracts  | 5              | 1          |
+---------------------------------------+----------------+------------+
| Interagency Acquisitions (IAs) (Up to | 41             | 3          |
| \$1M)                                 |                |            |
+---------------------------------------+----------------+------------+
| Construction Contracts                | 12             | 4          |
+---------------------------------------+----------------+------------+
| Architect & Engineering (A&E)         | 5              | 3          |
| Contracts                             |                |            |
+---------------------------------------+----------------+------------+
| Total                                 | 86             | 21         |
+---------------------------------------+----------------+------------+

The actions selected reflected a sampling across all procurement offices
and specialists as well as a variety of contract types and actions with
small and large businesses, universities, nonprofits, and foreign
entities.

The Self-Assessment Guide provides wide latitude and flexibility in how
Centers conduct their reviews and the specific areas scrutinized. The
last self-assessment examined procurement leadtimes, file documentation
(whether or not the proper file documentation was in the file and if it
was complete); and provided suggestions on how deficiencies and problems
noted could be improved.

The scope of this review was recommended as a consideration in the 2005
NASA HQ Procurement Management Survey Report. Therefore, the current
Self-Assessment Review concentrated on those areas previously identified
as having weaknesses in the last NASA HQ Procurement Management Survey
Report. Accordingly, it provides recommendations for regimented
corrective action and also includes comparisons with the previous NASA
HQ's Procurement Survey. A few of the items that surfaced as problems or
deficiencies in the prior NASA HQ's Procurement Survey Report were again
noted during this Self-Assessment. Possible reasons for this as well as
suggested solutions are contained in Attachment A, "Overall Assessment
and Recommendations".

# EVALUATION OF PERFORMANCE (NF 1680)

The NASA FAR Supplement Part 1842.15 requires Contracting Officers to
conduct interim evaluations of contractor performance using the NF 1680
(Evaluation of Performance) within 60 days of every anniversary of the
award of a contract having a term exceeding one year (with some
exceptions). All contracts requiring the evaluation of a contractor's
performance are tracked using the Past Performance Database (PPDB.) The
last Procurement Management Survey Report indicated that a majority of
NF 1680 forms were not completed on time.

## 

#### **[Findings (Evaluation of Performance (NF 1680)]{.underline}** {#findings-evaluation-of-performance-nf-1680 .unnumbered}

There were a total of 23 contracts included in the database, whose
reporting period ended in July 2006, of which 10 were included in this
review. We randomly sampled these 10 contracts, to determine if the
report had been completed appropriately. This sampling included a wide
range of contracts, GSA delivery orders, etc. For these 10 contracts,
the NF 1680s were due for completion within 60 days, in September 2006.
We reviewed the Past Performance Data Base (PPDB) data and contacted
Contracting Officers to evaluate the status of each of these NF1680
reports. The results of this review are as follows:

Of the 10 contracts that were reviewed, only two (or 20%) of the NF1680s
were completed by September, 2006. One NF 1680 was completed later in
January 2007 and two additional NF1680s are in progress, but not yet
completed. For these three cases (30%), Contracting Officers indicated
difficulty in getting timely COTR input that is required on the form.
The remaining five NF1680s (50%) had not been initiated when we
contacted the Contracting Officers. For these cases, several of the
Contracting Officers were either unaware of the reporting requirement,
or unaware that the requirement applied to their contract. Some of these
Contracting Officers were fairly new to NASA and had not yet experienced
this requirement. We sent instructions to several of these Contracting
Officers to educate them on the requirement/process and we will continue
to work with them through NF 1680 completion. In summary, , it was
determined that 80% of the randomly sampled files were delinquent in the
completion of the NF 1680.

Clearly, more Contracting Officer education and more diligent management
follow-up will be required for GSFC to be more successful in meeting our
NF1680 reporting requirements. Despite a PIP Topic presentation in
Fiscal Year 2006 and efforts to advise procurement staff via emails and
staff meetings, procurement has not successfully complied with the FAR
and NFS requirements for contractor performance evaluations. A random
polling of procurement staff indicated that non-compliance with these
FAR and NFS regulations are generally thought to be attributed to
increased workload and continued reductions in staffing. In prioritizing
contract actions, the completion of the NF 1680 seemed to take less of a
priority than other contract administration and new award functions.
Increased workloads and demands on time, make the completion of contract
administrative functions a challenge for the majority of contracting
persons.

Additionally, while much has been done to streamline the contract award
process during the many reforms of the 1990\'s, little has been done on
a regulatory basis to streamline the contract administration process.
With continued reductions in staffing, procurement on a federal level
struggles to meet the regulatory demands on the \"back-end\" of the
procurement process (Kelman, 2006.)

## **[Recommendations *(Evaluation of Performance (NF 1680))*]{.underline}**

It is recommended that there be an increased emphasis on tracking the
completion of the NF 1680. Similar corrective action has been
successfully implemented in the past (for example with cost plus award
fee contracts), and procurement is confident that this approach will
assist in remedying the problem. Additionally, we believe enhancements
to the PPDB that would provide email reminders as needed to contract
specialists may prove beneficial. The success of such reminders would
operate on the premise that the "squeaky wheel gets oiled" and that
after three reminders a supervisor is notified.

# COST PLUS AWARD FEE (CPAF) CONTRACTS

# 

# An identified weakness in the last Procurement Management Survey Report NAwas that GSFC should emphasize the need for timely approval of award fee plans (prior to contract award). Additionally, it was noted that few award fee determinations were made within the 45-day period specified in FAR 16.4 and NFS 1816.405-2 and that award fee evaluation results were not included in the Past Performance Database (PPDB).

## **[Findings *(CPAF Contracts)*]{.underline}**

Of the five new CPAF contracts awarded since the last Procurement
Management Survey Report, one was randomly selected and reviewed to
ensure that award fee plans are being approved prior to contract award.
This contract was awarded on July 1, 2006 and the Performance Evaluation
Plan (PEP) was approved on May 22, 2006. It is therefore in compliance.

There has been a vast improvement in issuing FDO letters. In April of
2006, FDO letters were on average 9.2 days late and by August of 2006
FDO letters were on average 2.6 days early! Procurement now successfully
tracks all 51 of its CPAF contracts and their subsequent Performance
Evaluation Boards (PEB's) and Fee Determination Letters (FDO). Doing so
has allowed procurement to closely monitor the time frame for ensuring
compliance with the NFS.

Procurement has significantly improved the turn around time for the
completion of PEB's and the issuance of FDO letters.

As noted above, procurement has made significant strides to improve
compliance in this area and the data supports this fact.

## **[Recommendations *(CPAF Contracts)*]{.underline}**

Procurement Personnel should continue to have award fee plans approved
prior to contract award and should continue to successfully track the
completion of all PEB's and FDO letters. The significant performance
improvement in this area since the issuance of the last NASA HQ
Procurement Management Survey Report is commendable

Procurement should consider the same tracking methods currently being
used for award fee evaluations to the evaluation of contractor
performance section of this report to help in that area and to ensure
that award fee evaluation results are entered into the PPDB in a timely
manner.

# INTERAGENCY ACQUISITIONS (IA's)

A total of 3 Interagency Acquisitions (IA's) with an order value of up
to a million dollars were randomly selected for review. The IA's
reviewed were with a variety of Government agencies. The last
Procurement Management Survey Report identified a weakness in
procurement\'s compliance with FAR 17.504 (c). Therefore, each IA was
reviewed to determine compliance with FAR 17.504 (c) and GSFC
Procurement Information Circular (PIC) 99-3.

## **[Findings *(IA Compliance with FAR 17.504 (c) and GSFC PIC #99-3*)]{.underline}** 

In one of the three files reviewed, a provision was not included for the
resolution of disagreements that may arise. Therefore, it was not in
compliance FAR 17.504 (c) and GSFC Procurement Circular #99-3.

All three of the files included statements of work that sufficiently
described the work or services being acquired including deliverables,
reports and delivery and completion dates. However, one of the files
reviewed cited Attachments A and B to the order but both Attachments
were still marked \"Draft.\". This appears to have been overlooked when
the award document was assembled.

Each file included a complete, signed D&F document.

All R&D orders included the latest Center for Aerospace Information.
This was updated in February 2003 (Rev. 4 of Circular 99-3).

The New Technology clause was included in all files reviewed.

## **[Recommendations *(IA Compliance with FAR 17.504 (c) and GSFC PIC #99-3*)]{.underline}** 

Overall, the IAs reviewed were in compliance with FAR 17.504 (c) and
GSFC Procurement Circular #99-3. Therefore, procurement will continue to
follow the guidance provided and ensure that procurement personnel use
the guidance available to them. As an added measure of ensuring the
accuracy of these orders, it is recommended that extra time be spent
reviewing these documents for compliance and administrative errors.

# CONSTRUCTION CONTRACTS

The GSFC Procurement was cited for two weaknesses in the area of
construction contracts in the last NASA HQ Procurement Management Survey
Report. The first weakness which referred to FAR 28.102-1 stated, "The
GSFC should when negotiating contract modifications increasing contract
value and/or extending contract performance periods, review the contract
documents to see if the changes affecting bonding, insurance,
subcontracting or other contractual requirements and take action to
update the files, as needed." The second weakness stated, "The GSFC
Procurement Officer should ensure that construction invoices that do not
include the data required by FAR 52.232-5, specifically in relation to
subcontractor data, are not processed." As a result of these two
weaknesses, this survey reviewed four construction contract
modifications awarded in fiscal year 2006 that increased either the
contract value or extended the period of performance to determine if the
bonding and insurance information was updated accordingly. Additionally,
four invoices were randomly selected from contract files that included
FAR 52.232-5. All four invoices were reviewed to assess their compliance
with the requirements set forth in FAR 52.232-5.

## [**Findings *(Construction Contracts****)*]{.underline}

Three Firm Fixed Price (FFP), Indefinite Delivery Indefinite Quantity
(IDIQ) construction contracts were reviewed. Two contracts were
completely compliant with the requirements set forth in FAR 28.102-1.
The basic contracts and subsequent modifications had performance and
payment bonds that were equal to 100 percent of the revised contract
value. One contract did not meet the requirements set forth in FAR
28.102-1. The performance and payment bonding information was equivalent
to the minimum IDIQ value of the contract (\$25,000) and therefore
insufficient to protect NASA's interests. Since the award of the
contract, several modifications had been issued on the basic contract
which increased the contract value to \$347,214.12. When interviewing
the contract specialist assigned to this file, the regulations under FAR
28.102-1 and FAR 52.228-15, seemed to have been misinterpreted.

One Firm Fixed Price contract with a change order modification was
reviewed. The bonding and insurance information was equal to 100 percent
of the revised contract value.

On one of the four invoices subject to the requirements of FAR 52.232-5,
it did not include a listing of the total amount of each subcontract
under the contract and there wasn't a listing of the amount previously
paid to each subcontractor under the contract. Moreover, it also
invoiced for various materials/equipment but did not furnish
satisfactory evidence that it had acquired title to such material and
that the material would be used to perform this contract. It did
however, include an itemization of the amounts requested and all of the
required certification statements identified in FAR 52.232-5.

The second invoice reviewed for compliance with FAR 52.232-5 did not
include an itemization of the amounts requested. It did however, include
the required certifications. There were no subcontractors on the
contract and therefore several of the requirements under FAR 52.232-5
were not applicable.

The third and fourth invoices reviewed for compliance with FAR 52.232-5
did not include an itemization of the amounts requested. None of the
required certifications were included on the invoices. There were no
subcontractors on the contract and therefore several of the requirements
under FAR 52.232-5 were not applicable.

## [**Recommendations *(Construction Contracts****)*]{.underline}

In most instances the construction contracts reviewed were compliant
with the requirements of FAR 28.102-1. In the one instance in which the
contract was not compliant it was identified as an unintentional
misinterpretation of the regulatory requirements and corrective action
is being taken to remedy this file. Procurement will continue to
emphasize the correct application and importance of the requirements set
forth in FAR 28.102-1.

None of the four invoices subject to the requirements of FAR 52.232-5
were completely compliant. It would appear that additional education in
this arena is needed. To remedy the problem, it is believed that the
checklist created and designed for this survey should be shared with
contract specialists to ensure that all future invoices are compliant
with the requirements of FAR 52.232-5. In addition, procurement staff
will be advised via email and staff meetings of the importance of
complying with this regulation. All certified invoices should include a
completed checklist prior to approval. Unfortunately, little time is
devoted to the approval of contractor requests for payment. Often times,
invoices are received and turned around in as little as a day. Contract
specialists should be provided the time necessary to perform such
important contract administration functions.

# A &E Contracts

Three of five A&E contracts were reviewed to determine whether
improvements had been made since the last Procurement Management Survey
Report. The last Procurement Management Survey Report identified three
weaknesses related to A&E contracts. The first weakness stated that,
"Contracting Officers should ensure the negotiated price for producing
and delivering the designs , drawings, and specifications are within six
percent of the estimated cost of construction per FAR 15.404 (c) (4)
(I)." The second weakness stated that, "Contracting Officers should
approve the architect-engineer contract payment requests as required by
FAR 52.232-10. Involvement in the payment process will allow the
contracting officer to monitor contract payments, ensure withholding of
contract payments are justified, and that final payments are not made
prior to receipt of release of claims." The third weakness which was
categorized under, "Task Order: Competition under Multiple Award and
Delivery Order Contracts" stated, " The GSFC Procurement Officer should
ensure that all awardees are provided a fair opportunity to be
considered for each A&E task order exceeding \$2,500 unless an exception
applies. The contract file should identify the basis for using an
exception to the fair opportunity process." (FAR 16.505 (b) (1) (i).)

## **[Findings *(A&E Contracts) *]{.underline}**

One FFP IDIQ A&E contract was reviewed to ensure that it was compliant
with FAR 15.404 (C) (4) (I) and FAR 36.609-1. The negotiated price was
within six percent of the estimated cost of construction contract and
was therefore determined compliant.

One FFP contract and one FFP IDIQ contract were reviewed to determine
compliance with FAR 52.232-10. Both contracts were in compliance and
included Contracting Officer signatures on the payment requests.

One FFP IDIQ multiple award contract was reviewed to determine
compliance with FAR 16.505 (b) (1) (i). The action reviewed did not
provide fair opportunity and the file included a Justification for Other
than Full and Open Competition which documented the statutory exception
under FAR 16.505 (2) (b) (iii), "Only One Responsible Source." The
action is therefore compliant with FAR 16.505 (b) (1) (i).

## **[Recommendations *(A&E Contracts) *]{.underline}**

Of the three actions reviewed, all were deemed compliant with requisite
FAR requirements. Therefore, it is recommended that procurement continue
to adhere to these requirements and continue to educate their staff
accordingly.

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# ATTACHMENTS TO THE SELF-ASSESSMENT REPORT 

# Attachment A\--Overall Assessment And Recommendations

Overall, the Self-Assessment Team found the procurement files reviewed
to be generally complete, well organized, and well documented. The chief
concern is that a few of the findings noted in the last NASA HQ
Procurement Management Survey Report [have not]{.underline} been
corrected. Moreover, these weaknesses were identified as repeat findings
in the previous assessment. All of this may be indicative of a systemic
problem in certain procurement areas (such as communication and
implementation of policy, guidance, and regulatory changes, and/or
inadequate or insufficient training) or it could be the result of the
high turnover in personnel experienced in the last few years.
Additionally, the repeat weaknesses that were identified were in the
area of contract administration. It would appear that more emphasis and
time should be allotted for the performance of contract administration
functions which seem to take less of a priority than new award
functions. Inconsistencies and oversights noted in the files may also be
attributed to heavy workloads, as well as, a workforce with a number of
relatively inexperienced personnel in terms of being new to procurement
or new to Goddard (with experience coming from another Government
agency). Regardless of the reasons, these findings need to be addressed
globally within the procurement community in an effort to eliminate some
of the more critical and obvious problems so that they will not reappear
in future audits and assessments. By doing this we should also improve
the overall quality of our procurement process and products.

A multi-pronged approach is suggested to tackle this problem, as
detailed below.

-   The comments and recommendations in this report should be
    communicated to Division Management (PODBOD, Senior Staff, and
    Procurement Managers) by means of e-mail (with follow-up or further
    discussion in a future Topic Staff meeting, if necessary). The
    comments and recommendations should then be conveyed to each
    procurement office through face-to-face meetings or other forums
    where contracting personnel can learn and discuss weak areas of
    contract administration. Meeting in small groups such as this should
    facilitate discussion and make presentation of the information more
    personal for each of the employees. They will be meeting within
    their own work group and may be more comfortable about discussing
    these issues and asking questions. Findings from both the
    Self-Assessment and the HQs Survey Report will be discussed since
    there are many duplicate areas of concern. This will also be an
    opportunity to provide the background of each report---purpose,
    intent, importance and timing of the Self-Assessments and NASA HQ's
    Survey Team review. One best practice being utilized successfully
    has been that of an Associate, who sends weekly Monday morning
    emails to all employees of her offices that provide with personnel
    news regarding Kudos received from customers, reminders of upcoming
    actions as well as areas of contract administration that need more
    attention, based on recent reviews of files as well as survey and
    audit findings.

-   Written guidance, as needed, should be disseminated to the
    procurement community.

-   An assessment of training needs and appropriate forums for this will
    be discussed with the Senior Staff member overseeing Human Capital
    Development.

-   As a division, and as a procurement culture, more

-   emphasis should be placed on the importance of contract
    administration functions. Contract administration functions and
    contract award function should be of equal significance. At present
    there is a disparity between the \"front- end\" procurement process
    and the \"back-end\" procurement process and the time devoted to
    these functions. Contract specialists at GSFC are responsible for
    both.

-   Finally, it is important to provide a closed loop process so that
    new knowledge and lessons learned as a result of this and future
    Self-Assessments and the HQ's Surveys are fed back into guiding
    documents, local policy, and training forums. Equally important is
    devising a way to measure success in this arena. Certainly one
    metric will be the results of the next Self-Assessment Review and
    NASA HQ's Survey. The primary areas of concern noted in this report
    should be targeted in future self-assessment reviews to assess if
    corrective actions taken have resulted in improvement.

-   

-   

-   **[Summary]{.underline}**

The procurement workforce is dynamic and industrious. The number of
actions of varying complexity and dollar value processed in any given
time period is overwhelming. It is sometimes difficult to maintain a
balance between quality and timeliness so the procurement workforce
often unwittingly compromises work quality to meet the mission needs and
requirements of our technical customers. It is important, however, to
take the requisite time to periodically stand back and objectively
examine our work products to ensure that quality is not unduly
compromised or eroded. Accordingly, with the goal of improving the
quality of the procurement work product and increasing the knowledge and
understanding of the procurement function, it is hoped that the variety
of communication methods detailed above will obtain the desired results.

**[Attachment B\--Checklist for the Contractor's Request for Progress
Payments in Accordance with FAR 52.232-5]{.underline}**

**CONTRACT NUMBER \_\_\_\_\_\_\_\_\_\_\_\_\_\_ INVOICE NUMBER/DATE
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

+-----+----------------------------------------------------------------+
|     | **FAR 52.232-5 (b) (1) (i)**                                   |
+-----+----------------------------------------------------------------+
|     | 1)  Is there an itemization of the amounts requested (related  |
|     |     to the various elements of work required by the contract)  |
|     |     covered by the payment request?                            |
+-----+----------------------------------------------------------------+
|     |                                                                |
+-----+----------------------------------------------------------------+
|     | **FAR 52.232-5 (b) (1) (ii)**                                  |
+-----+----------------------------------------------------------------+
|     | 2\) Is there a listing of the amount included for work         |
|     | performed by each subcontractor under the contract?            |
+-----+----------------------------------------------------------------+
|     |                                                                |
+-----+----------------------------------------------------------------+
|     | **FAR 52.232-5 (b) (1) (iii)**                                 |
+-----+----------------------------------------------------------------+
|     | 3\) Is there a listing of the total amount of each subcontract |
|     | under the contract?                                            |
+-----+----------------------------------------------------------------+
|     |                                                                |
+-----+----------------------------------------------------------------+
|     | **FAR 52.232-5 (b) (1) (iv)**                                  |
+-----+----------------------------------------------------------------+
|     | 4\) Is there a listing of the amounts previously paid to each  |
|     | such subcontractor under the contract?                         |
+-----+----------------------------------------------------------------+
|     |                                                                |
+-----+----------------------------------------------------------------+
|     | **FAR 52.232-5 (b) (1) (v)**                                   |
+-----+----------------------------------------------------------------+
|     | 5\) Is there additional supporting data in a form and detail   |
|     | required by the Contracting Officer?                           |
+-----+----------------------------------------------------------------+
|     |                                                                |
+-----+----------------------------------------------------------------+
|     | **FAR 52.232-5 (b) (2)**                                       |
+-----+----------------------------------------------------------------+
|     | 6\) Did the Contracting Officer authorize material delivered   |
|     | on the site (or at other locations) and preparatory work done  |
|     | to be taken into consideration?                                |
+-----+----------------------------------------------------------------+
|     |                                                                |
+-----+----------------------------------------------------------------+
|     | **FAR 52.232-5 (b) (2) (i)**                                   |
+-----+----------------------------------------------------------------+
|     | 6.a) Was consideration specifically authorized by this         |
|     | contract?                                                      |
+-----+----------------------------------------------------------------+
|     |                                                                |
+-----+----------------------------------------------------------------+
|     | **FAR 52.232-5 (b) (2) (ii)**                                  |
+-----+----------------------------------------------------------------+
|     | 6.b) Did the Contractor furnishes satisfactory evidence that   |
|     | it has acquired title to such material and that the material   |
|     | will be used to perform this contract?                         |
+-----+----------------------------------------------------------------+
|     |                                                                |
+-----+----------------------------------------------------------------+
|     | **FAR 52.232-5 (c)**                                           |
+-----+----------------------------------------------------------------+
|     | 7\) Did the Contractor furnish a certification?                |
+-----+----------------------------------------------------------------+
|     |                                                                |
+-----+----------------------------------------------------------------+
|     | **FAR 52.232-5 (c)**                                           |
+-----+----------------------------------------------------------------+
|     | 7.a) Did the certification include the statement, \"The        |
|     | amounts requested are only for performance in accordance with  |
|     | the specifications, terms, and conditions of the contract.\"?  |
+-----+----------------------------------------------------------------+
|     |                                                                |
+-----+----------------------------------------------------------------+
|     | **FAR 52.232-5 (c)**                                           |
+-----+----------------------------------------------------------------+
|     | 7.b) Did the certification include the statement, \" All       |
|     | payments due to subcontractors and suppliers from previous     |
|     | payments received under the contract have been made, and       |
|     | timely payments will be made from the proceeds of the payment  |
|     | covered by this certification, in accordance with subcontract  |
|     | agreements and the requirements of Chapter 39 of Title 31,     |
|     | United States Code.\"?                                         |
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|     |                                                                |
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|     | **FAR 52.232-5 (c)**                                           |
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|     | 7.c) Did the certification include the statement, \"This       |
|     | request for progress payments does not include any amounts     |
|     | which the prime contractor intends to withhold or retain from  |
|     | a subcontractor or supplier in accordance with the terms and   |
|     | conditions of the subcontract.\"?                              |
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