Insight by: Craig Stetson, Partner
March 30, 2020
MEMORANDUM: Class Deviation – Submission of Interim Vouchers Under Classified Contracts
The government implemented an initiative to accelerate payments to contractors to minimize contract performance challenges arising from COVID-19. This DoD class deviation allows contractors to submit interim public vouchers under classified contracts directly to the paying office and bypass the prior requirement to submit initially to the DCAA. Effective immediately, contracting officers are instructed in this deviation to direct contractors to submit interim vouchers directly to the applicable paying office.
Another government initiative to accelerate payments to contractors to minimize contract performance challenges arising from COVID-19. See DoD class deviation allowing contractors to submit interim public vouchers under classified contracts directly to the paying office and bypassing the prior requirement to submit initially to the DCAA. Effective immediately, contracting officers are directed in this deviation to direct contractors to submit interim vouchers directly to the applicable paying office.
Effective immediately, in response to the Coronavirus Disease 2019 (COVID-19) national emergency, contracting officers shall direct contractors to submit interim vouchers under classified contracts, using an appropriate method, directly to the disbursing office listed in the contract. Interim vouchers under classified contracts are considered provisionally approved by the Defense Contract Audit Agency (DCAA). Contracting officers shall require contractors to follow all program security protocols and to continue to safeguard program information when submitting interim vouchers that are considered provisionally approved.
Contractors have been required to submit interim vouchers to the Defense Contract Audit Agency (DCAA) in accordance with Federal Acquisition Regulation (FAR) 42.803(b)(1) and Defense Federal Acquisition Regulation Supplement (DFARS) 242.803(b)(i)(A) and (B). For some classified contracts, contractors submit interim vouchers outside the Procurement Integrated Enterprise Environment (PIEE) or other authorized unclassified system because of security restrictions. This deviation relieves the requirement for the interim voucher to be submitted to DCAA prior to payment. This class deviation remains in effect until rescinded. My point of contact is John Burns, who is available by telephone at (571) 372-6181 or by email at [email protected]
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