Proof that Vendor Invoices were Paid

Are you asking for what constitutes a "proper" invoice?  See para. (a)(3) of the clause at FAR 52.232-25, Prompt Payment, if that clause is in your contract -- in particular, see (a)(3)(x).  See also para. (b)(1) of the clause at FAR 52.216-7, Allowable Cost and Payment -- in particular, see (b)(1)(i).  If these clauses are not in your contract, look at whatever clauses are in your contract.

We always attach the invoice--but we also pay by credit card so the payment is reflected.  Generally, if you have a functional system with good controls, a copy of the invoice should be sufficient.  Government can always come back and ask for additional documentation.

Thanks ji20874, it looks like based on FAR 52.232-16, they can essentially ask for anything to support the invoice.

Roy, I got the clause number wrong but the clause name right -- I edited my posting.

roy.manninen said:

...it looks like...they can essentially ask for anything to support the invoice...

Well, yes, or no...

I cannot tell if you are talking about documentation to provide along with an invoice before payment occurs?  No, the Government cannot ask for anything the definition of a proper invoice is in para (a)(3)(x) of the clause at FAR 52.232-25, Prompt Payment, or whatever similar clause is in your contract -- it can only ask for whatever documentation the contract requires.  Or, are you talking about justifying a prior invoice after payment during a later audit?  Then, para. (g) FAR 52.216-7, Allowable Cost and Payment, will apply, and that will reach back to para. (b)(1)(i) of that clause, and the burden will be on the contractor to prove its entitlement.

roy.manninen said:

In regards to justifying ODC costs, what should be attached to show that vendor invoices were paid?

Roy, I cannot tell whether you are contractor or government. As has been posted, the government can request whatever backup it finds necessary, though if significantly more than customary, and if it creates an additional cost burden, the contractor may be entitled to an equitable adjustment. Maybe. It depends.

I remember a long time ago when our Navy customer wanted every single expense item on the invoice fully documented, right down to receipts for employee expense reports. We shrugged and said, "sure, you're the customer." It was a very large ID/IQ contract with multiple cost-reimbursable subKs and lots of travel. Multiple Task Orders (~300 with about half active at any given time). Multiple CLINs. Multiple ACRNS.

To accommodate our customer's request, we hired a (small) moving van to deliver the invoice each month, and charged that to the contract as a direct expense. With burdens. And profit.

The people who had to make all the copies and assemble the invoice were direct-charged, as well. With burdens. And profit.

The copies were made via our reproduction service center @ $0.04/page as I recall. Charged to the customer contract. With burdens. And profit.

The people who drove the van ~ 200 miles each way to deliver the invoice were direct-charged, as well. With burdens. And profit.

The Navy then hired two civilians to review our monthly invoices to make sure we weren't billing for unallowable costs.

I recall that time when they found a $0.75 exception for a bridge toll they considered to be unreasonable. ("Why couldn't you plan your route to avoid the bridge?")

Ah, government contracting. Good times.