Storage, handling, and contract files
FAR 4.805 mandates strict procedures and minimum retention periods for contract files to ensure legal and audit compliance, requiring agencies and contractors to manage records accurately and securely across all media.
Overview
FAR 4.805 establishes requirements for the storage, handling, and retention of government contract files, ensuring compliance with the National Archives and Records Administration (NARA) General Records Schedule 1.1. Agencies must develop procedures for managing contract records in all media formats, including electronic and microfilm, and may convert originals to alternate media if accuracy and integrity are maintained. The regulation specifies minimum retention periods for various contract-related documents, including contracts, payrolls, proposals, and records related to investigations or litigation. Agencies seeking shorter retention periods must obtain NARA approval. The rule also addresses the handling of mixed administrative and program records, requiring retention for the longest applicable period when segregation is impractical.
Key Rules
- Agency Procedures for Record Management
- Agencies must establish procedures for storing, handling, and disposing of contract files per NARA guidelines, covering all media types.
- Conversion and Integrity of Records
- Original documents may be converted to alternate media if the process preserves accuracy, completeness, and clarity, and protects against alteration.
- Retention Periods
- Table 4-1 outlines specific retention periods for different types of contract records, ranging from 3 years (e.g., construction payrolls) to 6 years (e.g., contracts, canceled solicitations), or until business use ceases or records are obsolete.
- Mixed Files
- When administrative and program records are mixed and cannot be separated, retain for the longest required period.
- Shorter Retention Requests
- Agencies must seek NARA approval to retain records for less time than specified.
Responsibilities
- Contracting Officers: Ensure contract files are managed, stored, and disposed of according to agency and NARA procedures; verify accuracy of record conversions; apply correct retention periods.
- Contractors: Submit required records (e.g., payrolls, certifications) and understand retention requirements for their submissions.
- Agencies: Develop compliant procedures, oversee record management, and request NARA approval for shorter retention periods if needed.
Practical Implications
- This section ensures contract records are preserved for legal, audit, and administrative purposes, reducing risk of loss or non-compliance.
- Contractors and agencies must be diligent in record-keeping and aware of retention timelines, especially for electronic records.
- Common pitfalls include premature destruction, improper conversion, or failure to protect data integrity, which can lead to compliance violations.