vvEPA
              United States
              Environmental Protection
              Agency
            Office of
            Solid Waste and
            Emergency Response
DIRECTIVE NUMBER: 9242.6-02

TITLE:  GUIDANCE FOR ORGANIZING ARCS CONTRACT FILES



APPROVAL DATE: 1/3/89

EFFECTIVE DATE: 1/3/89

ORIGINATING OFFICE: OERR/OPM/CORAS
               0 FINAL

               D DRAFT

                STATUS:
         [  ]  A- Pending OMB approval
         {  j  B- Pending AA-OSWER approval
         [  ]  C- For review fit/or comment
         [  ]  D- .In development or circulating

                       headquarters
               REFERENCE (other documents):
  OSWER      OSWER      OSWER
/£    DIRECTIVE   DIRECTIVE   Di

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                            Urmeo Sutes environmental Pottcuon Agency
                  QSWER Directive initiation Request
                              1 Directive Nume*r

                               9242.6-02
                                  3. Originator information
           Conuct Ptrson
         Ken Adams
.Man Coat
I  OS2AO
Office
 OERR/OPM/CORAS
      3. ruie
            GUIDANCE FOR ORGANIZING ARCS CONTRACT FILES
      4. Summary ol Directive (uiciuae onel sutement of purpose)
      Provides instructions  to the Regions for development of a consistent, yet flexible
      filing system for organizing and managing ARCS Contract Files
      S.K«yworas Superf urxi , CEHCIA, SARA
       ia. Does This Oireeavt Superseat Previous Oirectiv«(J)?
                                                [   I Yes    What directive (number, tffie)


      b. Does It Supplement Previous Direetive(s)?          I   1     I   j
                                        |	j No   |	j Yes    Whit directive (numb«r. ttfc)
       I No.
       Onff Lev*
         | A - Sc/ieo: by AA/DAA    [  | 8 - Signed by Offic* Oirwaor   [  [ C - For fl«*i«w & Comment   [  0 - In Oe^ttopmeir
            8. Document to be distributed to States by Headquarters?
                                   n
                            No
Thl« R«miMt M««u OSWCfl Directives Sy*tem Format Standards.
9. Signature of Lead Office Directives Coordinator
Betti C. VanEpps
10. Name and Title of Approving Official
Henry L. Longest II, Director OERR
Date
1/3/89
Gate
1/3/89
     EPA Form 1315-17 (Rev. S-<7] Previous editions are oosoiete.
   OSWER          OSWER               OSWER               O
VE     DIRECTIVE         DIRECTIVE        DIRECTIVE

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      i        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
      «                   WASHINGTON, O.C. 20460
                             JAN
                                                           OFFICE OF
                                                   SOLID WASTE AND EMERGENCY RESPCNS
                                       OSWER DIRECTIVE 9242.6-02

MEMORANDUM

SUBJECT:   Guidance for Organizing ARCS Cont2p;a
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                              - 2 -

Implementation:

     It is recognized that there tends to be some variation among
Regions in their approach to a file management system.   The
recommended system seeks to retain the flexibility needed to meet
the varying needs of Regional Project Officers (RPOs).   There is
also the need for some standardization given the number of reviews
which will continue to be conducted (EPA IG, GAO, etc.) as well as
periodic visits by Headquarters representatives.

     I expect the principles of the attached system to be followed
in order to assure a minimal level of consistency among Regions in
this area.

     Any questions concerning the above or the attached guidance
may be addressed to Ken Adams or Debbie Dietrich, Acting Director,
Contract Operations, Review and Assessment Staff (CORAS) at
475-9337.

Attachment

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                                                      OSWER  DIRECTIVE  #9242.6-02
                  GUIDANCE FOR ORGANIZING ARCS CONTRACTS FILES
       This  guidance recommends  a  standardized ARCS contracts file management
 system for  Regional Project Officers  (RPOs).   A standard and consistent file
 organization  in every Region is necessary because of the quantity and complexity
 of  the documents  that  will be  generated by the ARCS  contracts.   A standard
 system should serve  several important  functions:

            •      Simplify  access  and  retrieval.     Access  and
                   retrieval will be simplified.  The first document
                   in each file  will be an index listing the file
                   contents.   Other documents  in  the file will be
                   categorized and arranged in separate file sections
                   or subsections,  by category.  For example,  in the
                   work assignment management file, the first section
                   may include all work assignments for a given site
                   arranged in chronological order.

            •      Provide  continuity.   As a kind of  "institutional
                   memory,"  a standard organization will ensure that
                   all necessary documents  related  to costs, site
                   activity,  contract  management,   and contractor
                   performance are  retained and retrievable.  Thus,
                   even if personnel turnover occurs, key information
                   will continue to be available as long as required.

            •      Facilitate review.  A standard organization will
                   facilitate contract management oversight and site
                   review   activities  of  Congress,  the  General
                   Accounting Office  (GAO),  the  EPA  Inspector
                   General,  and  other Agency groups.

      The recommended organization serves these functions while  retaining the
flexibility necessary to meet the  varying needs of Projects Officers (POs).

      Exhibit  1  lists  the  majority  of  the  documents that  will  have  to  be
maintained in ARCS contract  files  and briefly describes their functions.
The list of documents in Exhibit  1  is  not exhaustive.   Some of  the documents
included in the file illustrations below are not discussed.  These are routine
contract documents that are not ARCS*specific,  such as procurement requests and
equipment lists.   Also, substantive programmatic documents such as preliminary
assessment or  RI/FS  reports, for  example,  are  not  included.   These documents
form part of the administrative record supporting site decision-making and will
be  retained  in  the  administrative record file.     There  may be  additional
documents that are part of  the  decision-making process, but are also pertinent
to  work assignment  management,  e.g.,  certain technical  directives.    Such
documents should be retained in  both  the  administrative record and the ARCS work
assignment management file.

      ARCS documents should be  organized in five files:

            A.     A  general  contract   management  file,  organized  by

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                                                    OSwtiR   DIRECTIVE- #9242. 6-02
                  contract:;
            B.    A work assignment management file,  which may be
                  site-specific;
            C.    A financial and progress report file;
            D.    A performance evaluation file; and
            E.    A confidential  file.

      Each  file  may  occupy a file drawer,  a portion of a  drawer,  or  several
drawers.   The  files,  however,  must  be  divided into  the recommended sections.
Each file  section should be clearly identified and labeled.   An index  listing
the sections  should  be  the first document  in each file.  All  documents  in a
single category should be  filed together in a separate section or subsection,
e.g., all work assignments  or work assignment completion reports.   Within each
section, where practicable, documents should be arranged in chronological order
with the most recent documents filed at the  front  of the section.   The  length
of the retention period for each category of documents will be determined by the
PO and Contracting Officer, pursuant to the Federal Acquisition Regulation (see
48 CFR 4.8, October  1,  1987 ed.).

      The  following  file  illustrations  show  the  documents  that  should  be
included in each file and the  recommended sequence of document sections.
A.    Contract Management File
                 • • •**»#•••••••*
                  yea gyre-i
       COTWKI


mommHm
ciUodtcnoni
rta-i

RACT
EMENT



•

        FILE
                        For each ARCS contract, the
                  contract  management  file will
                  contain   documents   directly
                  related  to  the  ARCS  contract,
                  such  as   the  contract  itself,
                  contract    modifications,
                  management plans, documentation
                  relating  to  work distribution
                  and  the   exercise  of contract
                  options,  and routine contract
                  documents that  are  not  ARCS-
                  specific,  such  as  equipment
                  lists.
B.    Work Assignment  Management File
              ««n« tne. OP Fcm Ml

     nau
  WORK ASSIGNMENT

     MANAGEMENT

          FILE

   (can be site-specific)
  worn
[ASSJOMCNlj
  SECTON
      The   work    assignment
management  file  may be  site-
specific.  It will contain all
work   assignments   and   work
assignment    amendments,
workplans, activity reports , and
all  correspondence  (including
cover letters from deliverables)
related to a given site. Routine
contract  documents,   such  as
procurement requests, will also
be   included   in   the   work
assignment management  file.

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                                                      OSWER DIRECTIVE  #9242.6-02
 C.    Financial and Progress Report File





| A^^.cj^c.H.uu.1* 	
I AnnunMooan fl«oortt
| Monwy PfooTM* (Moani
fw»o««
| >no«i
FINANCIAL AND
PROGRESS REPORT
DOCUMENTATION
FILE



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                                                      The financial and progress
                                                report documentation file will-
                                                contain monthly progress reports
                                                and other cost-related documents
                                                such    as    invoices,   annual
                                                allocation  reports, and annual
                                                analytical  service reports.
D.    Performance Evaluation File
     
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                                                             *>iKjtL'i'IVE  #9242.6-0
      Regional contract management  personnel  who  identify additional ARCS  or
routine contract documents that have not been included in this recommended plan,
or have questions or suggestions regarding  file management, should notify  Ken
Adams of the Contract Operations Review and Assessment  Staff,  FTS  #8-475-9337
EPA mail code OS-240, EPA electronic mailbox EPA 5240.

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                                                                      EXHIBIT 1

                    DOCUMENTS THAT PRESENTLY NEED TO BE RETAINED IN ARCS CONTRACT FILES
                    Document
                                              KiiMctlon
Contract Management Pucumeats

Contract and Coniraci Modifications

Management Plan


Work Distribution Documentation

Documentation of Exercise of Contract
Options

Work Assignment Management Documents

Work Assignment


Work Assignment Amendment

Work Plan (incl. OP Form 60)
Activity Kt|M>n


Financial «nd Progress Report Documents

Invoice

Monthly Progress Kepon
Agreement between EPA and contractor staling terms according to which work will be performed.

Plan for managing the contract including the purpose and scope of the project, the management process, subcontracting.
property management, the technical approach, quality assurance plans, and health and safety plan.

(Specific documents required in this category have not been determined.)

(Specific documents required in this category have not been determined.)
Vehicle used by EPA to assign work to contractor; includes work description, a Holed LOE. duration of assignment, and
scheduled completion dale.

Modification to add to or change work assigned, hours, duration, etc.

Required for each work assignment; serves as a baseline to monitor contractor's progress; must include a detailed cost
estimate identifying all major cost items, staling objectives of proposed activity, and describing relationship to other
activities, technical approach, and work to be performed under each task; must also include safety measures, schedule.
number of person-hours required, cost flow arid control procedures, subcontracting, and document production and
distribution.

Documents the completion of work assignments, conduct of work; presents findings, conclusions, and recommendations;
accounts for funds expended; provides guidance for future activity.
Written request for payment under the contract for supplies delivered or for services rendered.

Informs Project Officer (PC)). Regional Managers, and the Remedial Project Managers (RPMs) of the status of individual
activities and the overall program for the reporting period; provides baseline for planned expenditures for each site and
work assignment; calls attention lo departures from management and work plans. Consists of Iwo parts:

      Summary Progress Report -- pertinent technical and financial information describing contractor efforts on all
      work assignments; summarizes expenditures, estimates LOE and costs required for completion; includes
      spread sheet comparing actual and budgeted expenditures.

      Site-Specific Report -- supplies technical and financial summaries for each woik assignment on a site-
      specific basis.

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                           ;*.»•> V  U
                          jfi/Mte
                                                 IT 1 (CONTINUED)

nnr-jIMPMTC TpiAT PPPSFNTI v NEEI)rTO^BE RETAINED IN ARCS CONTRACT FILES
                                                                                                 FunclBon
 „     - .,fcJ»JW*»<*<|«lll<. j»".. <, .-'.'
Annual Allocauan Report
       ..           ..
 Anilylicii Services Repor
  .
Conlraclnr Self- Evaluation Report
 Summary Evaluaiion Report (SER)
 Regittnal Eveiualion Summary (RES)
              ,             -
 Perriirmancc Event Repon (PER)
 Phase I Award Fee Allocation Matrii
..'.v-tj ,*.      .       • •  .   siMii--
        •    -       ' ..      ', Mki-
 Phase II Award Fee Allocation Matm
 Performance

 Award Fee Modifications
                                                               fiaed and awerd fees, and some nonrsite activity costs to sites and activities for
                                                                  Federal fiscal year.
                              Annual report on use of non-CLR)eboralorics and analysis of the effectiveness of the services provided.

                                       rVJMV.of <•••  ,
                                                                   contractor's performance of specific work assignment used to identify difficulties or trends and
                                                                   *  «''•?«  • * 'fi'tt--  V'  *   f *• ..*' »\   • •
                                                                                               ped improvement.
                           , ,KtoWaefor's self -evaluation of performance for. |hc relevant period for consideration by the Performance Evaluation
                             1 j^rojcci iJiHCer a oversllrev^WaUon pased on contractual cntena and rating guidelines; considers two categories - -
                            ,'..'• project management office activities erad technical performance of remedial work assignments; identifies recurring
                            ^^difficulties and trends; irjAcales wwik assignments upon which evaluation is based. (Contracting Officers also prepare
                             ~>A^hij^|i?}£;ttay i»«PVn|iEkfii&&>lh caietories for consolidation with the PO's evaluation.)
                                                                                         tive work assignment for use of Performance
                                       --»• v -   •   - 'witwwn «.«       —"d fec: r*ICS P*ffomi-nce •fld F0*'*" of *P«ific projects, and
                                       s'aVerage or above averagc;perforrgjuice; incorporates information on specific problems from the Performance
                                                                  "
                                          ss than satisfactory per/prmance of an area of work or work assignment; vehicle for affecting the
                                             d fee and-ftbiPEfi s use in determining the final amount of the Phase II award.
                              Table suritimVtoing costs and'^Ehase..! award fees by work assignment prepared for trimester evaluation by the contractor
                              and verified rJPlhe ConOi^^^j^i^^tthe P^B's use in determining the Phase I (contract-wide) award fee.

                              Prepared at the conclusion of work assignments; summarizes olte evaluation made by the Region, the contractor, and the
                              Report and recommendalion of the PER after determination of award fees.
                              ;, \)f
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