Vern,

At SMC, the common practice of most buyers is to put the following information in block 14 of the SF 30: change in contract value (if any), obligation amount (if any), a one line description of the modification, and a blurb that says see attached page(s). The attached page(s)(continuation of block 14) then include very specifically by UCC order both the purpose of the modification and explicit detail of the changes to the affected sections of the contract(i.e. b, f, g.,etc.). Hope this helps.

By Joel Hoffman on Friday, May 12, 2000 - 01:46 pm:

I haven't read those instructions for block 14 in detail in a long time. Most of the Corps of Engineers Districts do not cite the reason for the modification (at least for construction contracts),in block 14. We confine block 14 to a clear description of all changes in the contract terms.

We tend to fall back on pre-FAR documentation practices, documenting "the reason for the modification" and the "reason for omission from the plans and specifications" in other documents.

The resource management folks' generally require documentation to satisfy the "bonafide needs Rule" for the funds. So, the funds commitment documentation will often include the reason why the mod is necessary, long before a mod is written.

The Corps used to require various formats for a "Findings of Fact" or required us to use an old DOD Form as aprice negotiation memorandum to document the reason for the mod and the explanation why the work wasn't in the original contract. Now days, most formats for the "Price Negotiation Memorandum" and/or "Pre-Negotiation Objective Memorandum" capture this information.

The Corps also kept statistics on "reason codes" for mods; there were various ways to capture that data element.

So why repeat the info on the SF-30? It is extraneous to the info otherwise in the mod file. I don't recall any contractor being overly interested in such documentation.

The excuse that auditors can review the SF-30 to validate the reason for the action doesn't save them any time. Anyone auditing our change process or mods ALWAYS review the mod files, anyway! Happy Sails! Joel

By Kennedy How on Friday, May 12, 2000 - 12:46 pm:

Verne,

In my former office, we didn't have to do any kind of formal "Determinations and Findings" sort of documentation as to why a Contract Modification had to be issued. Usually, we would get various requests to do something, or to tell the contractor to do something, and that was good enough for most of us. We would officially document the file when needed, i.e., when we did a supplemental agreement, and we had pricing reports, PNMs, etc.

In those cases where the contractor is requesting a change, usually there is sufficient documentation outlining why it's needed, and there is some concurrence and approvals before this is needed. Back in the days when we used the "DF", we'd have a blizzard of paper and flimsies. Today, it's Outlook mail.

Now, it's our practice to set forth exactly what the mods do in BLOCK 14 (or, most likely, on a Continuation sheet). Basically, mine usually said "The purpose of this modification is to incorporate (ECP, RFD/W, Delivery Schedule Extension, etc.) into (whatever)." There were those instances where we'd write a mod to incorporate additional scope of work on a ceiling price basis, change order obligate some amount of money to cover it, and get the contractor working. We put in language to have him submit a proposal within some amount of time, for definitization.

Finally, I've seen pretty wordy mods issued by some systems buyer types. I kinda wondered about those, but each buyer/PCO had their own methods, and sometimes those are driven by who the contractor is.

Kennedy

By Vern Edwards on Friday, May 12, 2000 - 11:15 am:

P.S. We both know that the instructions on the back of SF30 say to state the reasons for the mod in block 14, but neither of us believed that this, in and of itself, was sufficient to justify doing so.

By Vern Edwards on Friday, May 12, 2000 - 11:11 am:

I'd like some input:

A friend and I were discussing contract modification practices and we found that we disagreed on one issue. The issue was whether the CO should document the background and reason for the modification in block 14 of Standard Form 30 or in a separate memo to file. We have seen it done both ways and each of us had good reasons for preferring one way or the other.

I know that this is a fairly minor practice issue, but I wonder if any of you have a preference or if your office has a policy in this regard.