PROCUREMENT 101 The Essentials Building Blocks POLICIES AND

PROCUREMENT 101 “The Essentials”

Building Blocks POLICIES AND PROCEDURES ADMINISTRATIVE REGULATIONS KENTUCKY MODEL PROCUREMENT CODE

Kentucky’s Procurement Law n n American Bar Association’s (ABA) Model Procurement Code was adopted by Legislation in 1978 and became law in 1979. Kentucky was the first state to adopt this procurement code. There are currently 18 states operating under this code. KRS Chapter 45 A is the statutory location of the Model Procurement Code.

Kentucky’s Procurement Law • ABA drafted the MPC as a result of numerous public purchasing scandals across the country; • It’s a Model Code and not a Uniform Code; • Highly flexible statutory framework; • Establishes a set of ethical standards.

n n n n KRS 45 A. 010 - Purposes and Policies (2) The underlying purposes and policies of this code shall be: (a) To simplify, clarify, and modernize the law governing purchasing by the Commonwealth; (b) To permit the continued development of purchasing policies and practices; (c) To make as consistent as possible the purchasing laws among the various states; (d) To provide for increased public confidence in the procedures followed in public procurement; (e) To insure the fair and equitable treatment of all persons who deal with the procurement system of the Commonwealth; (f) To provide increased economy in state procurement activities by fostering effective competition; and (g) To provide safeguards for the maintenance of a procurement system of quality and integrity.

KMPC n KRS 45 A. 050 – KRS 45 A. 340 State Government – – – n 45 A. 050 – 45 A. 067 – Definitions, Exemptions to centralization of procurement, Finance Cabinet authority to promulgate Regulations; 45 A. 070 – 45 A. 170 – Methods of awarding state contracts, Competitive Sealed Bidding, Competitive Negotiation, Small Purchases; 45 A. 180 – 45 A. 340 – Capital Construction, Bonds, Protests, Conflicts of Interest; KRS 45 A. 343 – KRS 45 A. 460 Local Governments

KMPC n n n KRS 45 A. 500 – 45 A. 540 - Recycled Material Content Products KRS 45 A. 550 – 45 A. 570 Privatization Contracts KRS 45 A. 600 – 45 A. 725 Miscellaneous Procurement Provisions – Personal Service Contracts

KMPC n n KRS 45 A. 730 – 45 A. 750 – Procurement of Architectural and Engineering Services KRS 45 A. 800 – 45 A. 838 – Architectural and Engineering Services KRS 45 A. 840 – 45 A. 879 – Underwriter and Bond Counsel Services KRS 45 A. 990 – Penalties

KRS 45 A. 990 - Penalties n KRS 45 A. 045 – Disposal of Surplus Real and Personal Property – Class D Felony n KRS 45 A. 325 – Collusion – Class D Felony n KRS 45 A. 330 to 340 – Conflicts of Interest – n Class B Misdemeanor KRS 45 A. 690 to 725 – Personal Service Contracts – Class A Misdemeanor

Administrative Regulations Title 200 Chapter 5 For Example: n 306 - Competitive Sealed Bidding n 307 - Competitive Negotiations n 310 - Multiple Contracts n 312 - Termination of Contracts n 380 - Protests

Competitive Sealed Bidding n KRS 45 A. 080 Competitive sealed bidding – n (4) Bids shall be opened publicly at the time and place designated in the invitation for bids…. 200 KAR 5: 306. Competitive sealed bidding – Section 2. The purchasing officer or other employee of the purchasing agency designated to open the bids shall determine when the time set for opening bids has arrived and shall so declare the time to those present for the bid opening. The purchasing officer or designee shall, in the presence of all persons in attendance, open all bids received as of that date and hour. If practical, the names of the bidders and the amounts of their bids may be read aloud to the persons present.

Policies and Procedures n FAP 111 -35 -00 Competitive Sealed Bidding – 10. Opening of Bids: At the time designated for bid opening, online and hardcopy bids shall be opened and may be read or otherwise made available to the public. No late online bid responses shall be received or considered. A hardcopy bid received after the time specified in the Solicitation shall not be considered, unless no other bids are received.

Familiarize Yourself With the Following in the Policies and Procedures Manual: n FAP-111 -08 -00 n n FAP-111 -09 -00 n n FAP-111 -10 -00 n Exceptions to Sealed Bidding (By Law or Regulation) Exceptions to Sealed Bidding (Not Practicable / Feasible) Exceptions to Sealed Bidding (Sole Source)

Four Basic Methods of Procurement Under KMPC (KRS 45 A) n n Competitive Sealed Bidding (KRS 45 A. 080) Conducted by FAC’s Office of Procurement Services for aggregate purchase of $20, 000 or more. Competitive Negotiations - RFP (KRS 45 A. 085) Large dollar amounts - Determination and Finding required. Non-Competitive Negotiations (KRS 45 A. 095) Examples: Sole Source, Emergency- Determination and Finding Required. Small Purchases (KRS 45 A. 100) Aggregate amounts less than your agency’s authorized dollar amount. Most agencies = $1, 000 with single quote.

Kentucky Preference Laws

KRS 45 A. 494 - Reciprocal preference for Resident Bidders “Prior to a contract being awarded to the lowest responsible and responsive bidder on a contract by a public agency, a resident bidder of the Commonwealth shall be given a preference against a nonresident bidder registered in any state that gives or requires a preference to bidders from that state. The preference shall be equal to the preference given or required by the state of the nonresident bidder. ”

Tie Bid If a procurement results in a tie between a resident bidder and a nonresident bidder, preference shall be given to the resident bidder.

KRS 45 A. 494 – Reciprocal Preference for Resident Bidders n n n Applicability Applies to all contracts funded or controlled in whole or in part by a public agency. “Contract” means any agreement of a public agency, including grants and orders, for the purchase or disposal of supplies, services, construction, or any other item. “Public agency” has same meaning as KRS 61. 805 (Open Meetings Law definition).

KRS 45 A. 494 - Reciprocal preference for Resident Bidders 1. 2. 3. Resident Bidder An individual, partnership, association, corporation, or other business entity that, on the date the contract is first advertised or announced as available for bidding; Authorized to transact business in the Commonwealth; and For 1 year prior to and through the date of the advertisement, filed Kentucky corporate income taxes, made payments to the Kentucky unemployment insurance fund established in KRS 341. 490, and maintained a Kentucky workers' compensation policy in effect.

KRS 45 A. 494 - Reciprocal preference for Resident Bidders Nonresident Bidder An individual, partnership, association, corporation, or other business entity that does not meet the requirements to be considered a resident bidder.

KRS 45 A. 494 - Reciprocal preference for Resident Bidders 1. 2. Other Requirements The Finance and Administration Cabinet shall maintain a list of states that give to or require a preference for their own resident bidders, including details of the preference given to such bidders, to be used by public agencies in determining resident bidder preferences. The cabinet shall also promulgate administrative regulations in accordance with KRS Chapter 13 A establishing the procedure by which the preferences required by this section shall be given.

KRS 45 A. 494 - Reciprocal preference for Resident Bidders Other Requirements (cont. ) 3. 4. The preference for resident bidders shall not be given if the preference conflicts with federal law. Any public agency soliciting or advertising for bids for contracts shall make KRS 45 A. 490 to 45 A. 494 part of the solicitation or advertisement for bids.

200 KAR 5: 400. Kentucky Resident Bidder Reciprocal Preference. Section 1. Definitions. (1) "Contract" is defined by KRS 45 A. 490(1). (2) "Nonresident bidder" is defined by KRS 45 A. 494(3). (3) "Public Agency" is defined by KRS 45 A. 490(2). (4) "Resident bidder" is defined by KRS 45 A. 494(2). (5) "Response" means any bid or response submitted to a solicitation. (6) "Solicitation" means an invitation for bid, request for proposal, advertisement for bid, or another formal method of soliciting a contract issued by a public agency.

200 KAR 5: 400. Kentucky Resident bidder reciprocal preference. (1) Claiming Resident Bidder Status Any individual, partnership, association, corporation, or other business entity claiming resident bidder status shall submit along with its response a notarized affidavit that affirms that it meets the criteria to be considered a resident bidder as set forth in KRS 45 A. 494(2). Failure of a Ky. bidder to submit will not disqualify a vendor from bidding; however, they will not be eligible to be considered as a “resident bidder”. A vendor can not take exception to any part of the affidavit in order to be eligible for “resident bidder status”. (2) If requested, failure to provide documentation to a public agency proving resident bidder status shall result in disqualification of the bidder or contract termination.

200 KAR 5: 400. Kentucky resident Bidder Reciprocal Preference. Determination of Residency for Nonresident Bidders 1. The state of residency for a nonresident bidder, for purposes of this administrative regulation, shall be its principal office as identified in the bidder’s certificate of authority to transact business in Kentucky as filed with the Commonwealth of Kentucky, Secretary of State. 2. If the bidder is not required to obtain a certificate of authority to transact business in Kentucky, its state of residency shall be deemed to be the mailing address provided in its bid.

200 KAR 5: 400. Kentucky Resident Bidder Reciprocal Preference 1. 2. 3. Applying the Reciprocal Preference Once all responsible and responsive bidders to a solicitation have been scored and ranked, the residency of each bidder shall be identified. A preference equal to the preference given or required by the state of the highest evaluated nonresident bidders shall be given to all responsive and responsible resident bidders. The responses shall then be rescored and re-ranked to account for any applicable preferences.

200 KAR 5: 400. Kentucky Resident Bidder Reciprocal Preference Applying the Reciprocal Preference (cont. ) 4. In awarding a contract, resident bidders shall only receive preference against nonresident bidders residing in a state that gives a preference to bidders from that state. This preference shall not be applied against nonresident bidders residing in states that do not give preference against Kentucky bidders. 5. If a procurement determination results in a tie between a resident bidder and a nonresident bidder, preference shall be given to the resident bidder. 6. Nothing in this administrative regulation shall result in a nonresident bidder receiving a preference over another nonresident bidder.

Secretary of State Registration? n Will this new law require all resident vendors who wish to bid on a contract to be registered with the Sec. of State’s Office? – The reciprocal preference law does not impose any additional requirements on a vendor with regard to registering with the Secretary of State. A resident bidder will fall into one of these three categories: – 1) Organized under the laws of Kentucky which would require registration with the Secretary of State; – 2) Organized under the laws of another state but doing business here which would require that they receive a certificate of authority to transact business in Kentucky from the Secretary of State; or – 3) Not required to register with the Secretary of State (sole proprietorship, for example). – Therefore, the category in which they fall will determine what form of registration, if any, is required.

Next Steps n n This information will be posted to our eprocurement website: http: //eprocurement. ky. gov/ The Oregon website that contains a list of all state preferences is: http: //procurement. oregon. gov/DAS/SSD/SP O/reciprocal_detail. shtml. Ky is in the process of creating our own list of state preferences, but we will use the Oregon site initially.

THE LAW n n 1. ) Procurements not to exceed an aggregate amount of $1, 000 for all other purchases by state governmental bodies may be made in accordance with Small Purchase Regulations promulgated by the Secretary of the Finance and Administration Cabinet. 2. ) Procurement requirements shall not be artificially divided so as to constitute a Small Purchase under this section. Ref: KRS 45 A. 100 Policy: FAP-111 -55 -00

Definition of Aggregate: n Gathered together in a mass constituting a whole.

Basic Small Purchase Procedure

Price Quotes Required for Finance Cabinet Agencies

Quotations Required for Commodity & Service Purchases

Construction Services Quotes Required

“Tips” When Obtaining Quotes From Vendors n n n If obtaining phone quotes - advise vendor(s) you’re obtaining quotes from several vendors. For FAX quotes, have vendor fax his quote, terms, etc. to you complete with his signature. Write legible if you’re obtaining quotes by fax machine. Always give a complete address for the “Ship To” location -- Don’t use P. O. Box Numbers!! If possible, always make freight terms F. O. B. Destination --- not F. O. B. Factory!

“Tips” When Obtaining Quotes From Vendors n n Contact the manufacturer if a Brand Name is required to determine authorized dealers to promote competition. If you have a higher small purchasing authority (I. e. $5, 000 or more), consider establishing an acceptable brands list (ABL) when soliciting. ADVANTAGE of ABL Promotes Competition DISADVANTAGE Requires research and hands on evaluation of products -- can be time consuming.

Specifications n n Learn all you can about preparing specifications -- especially when the bid requires a formal solicitation ($20, 000 plus) There are various workshops and/or seminars available to you. – National Institute of Governmental Purchasing (NIGP) is an excellent source.

Submitting Specifications on e. MARS Requisitions • General or Generic Specifications • Brand Name or Approved Equal • Acceptable Brands List • “No Substitute” Requisition BEWARE!!!! - Competition Killer

Definition Of a TERM CONTRACT Price agreements with a particular vendor to supply specific items at a specific unit price for a specific period.

Term Contracts When Should a Term Contract be Used? 1. To provide a continuing need 2. To expedite the normal purchasing process (i. e. obtaining quotes) Why are Term Contracts Established? 1. Convenience of User 2. Variety at a Fixed Price 3. Accelerates the Bid process

GSA n What is the General Service Administration (GSA)? The procurement agency of the U. S. government n What is a GSA Price Agreement? A non-competitive negotiation between a vendor and the federal government which results in a 5 to 10 year contract.

45 A. 045 Authority of Cabinet (7) Nothing in this section shall deprive the Finance & Administration Cabinet from negotiating with vendors who maintain a general service administration (GSA) price agreement with the United States of America or any agency thereof.

RQ MA PO AOC Terms & Acronyms to Know Requisition Price Contract Prefix “Guaranteed” Contract Prefix Advice of Change to amend a Price Contract RFQ RFB RFP IT D&F 45 A 200 KAR Chapter 5 Addendum BREACH Request for Quotation PROTEST Vendor formally protesting an award decision Request for Bid Request for Proposal Prefix to identify an IFB Determination and Finding KY’s Model Procurement Law Purchasing Administrative Regulation Official changes to RFQs, RFBs, & RFPs Contractor is in default of contract requirement(s)

Be Aware of Procedures Pertaining to Recycled Content in Products Purchased. n SOURCES: – KRS 45 A. 500 to. 540 – 200 KAR 5: 330

POST AWARD CONTRACT MANAGEMENT

POST AWARD CONTRACT MANAGEMENT n n n n Overview of Types of Contracts and Award Methods Understanding the Contract – Contents of the Contract Performance – Designating an agency contract manager, receiving goods or services, monitoring performance, approving payment, evaluation of performance Contract Modifications Performance Problems, Complaints, and Resolution – Contract Termination – Disciplinary Action Creating and Maintaining Records Assignment of Contract or Assignment of Payments

WHAT IS CONTRACT MANAGEMENT? The management of all actions, after the award of a contract, that must be taken to assure compliance with the contract; e. g. , timely delivery, acceptance, payment, closing contract, etc. Every agency should designate a programmatic contract manager for each contract they administer.

CONTRACT TYPES AND AWARD METHODS n n n Competitive Sealed Bidding – KRS 45 A. 080 Competitive Negotiation – KRS 45 A. 085 Noncompetitive Negotiation – KRS 45 A. 095 Small Purchase by state agencies – KRS 45 A. 100 Personal Service Contract – KRS 45 A. 695 Memorandum of Agreement – KRS 45 A. 690 ***Includes any kind of contract- one-time, Delivery Orders, Master Agreements, PSCs, MOAs ****A payment for a good or service cannot be made without the proper authority!!!

CONTRACT TYPES AND AWARD METHODS The “contract” will be the official notice of award, which will begin the process of contract management. The vendor must receive an official contract/order from the Commonwealth that authorizes the purchase or notifies them to begin work.

Understanding the Contract n Contents of a Contract – Contract components and order of precedence n Solicitation, addenda to solicitation, vendor’s response to the solicitation – Contract Sections n Line items and pricing n Scope of work/Specifications n Deliverables and payment triggers n Negotiated items (where applicable) n Contract amount and budget n Contract period and renewals n Standard Terms and Conditions

Contract Performance n n n Awards of state contracts are made in accordance with the evaluation criteria set forth in the solicitation. In many instances vendors are awarded points based on their delivery of a product or contract milestones, which may have resulted in their receipt of the award. It is essential that the contract manager verifies that the contractor complies with all contractual requirements.

Contract Performance n What should be considered in managing a contractor’s performance? – Deliverables (milestones) – Quantity of goods to be delivered and/or services to be performed – Meets required specifications – Schedule n Completion of project and implementation – Outcomes n Were the savings projected from using this new product or service achieved. – Budget/financial issues n Timeliness of invoicing n Necessity of contract modifications – Customer service level

Contract Performance n n Who manages the contract? Commonwealth Buyer from the contract-issuing agency – Point of contact for all communications related to the contractual terms and conditions. n Renewals, change orders, modifications, or terminations must all come through the Buyer to be valid and enforceable. Using agency designated contract manager – An employee from the program agency responsible for the performance to be achieved through the contract – Responsible for enforcing performance of the contract terms and conditions and serve as a liaison with the contractor.

Contract Performance n n As a Contract Manager, How Do I Monitor Performance? Communicate initially with the vendor to set expectations and cover the four basic elements of contract performance – Contract requirements n Scope of work, deliverables – Schedule n Milestones, completion – Budget n Contract delivered within original budget. Accuracy, adequacy and timeliness of invoices, invoice processing and payment. Financial reporting if required. – Customer service level n What level of support and access are you going to expect? Reiterate these requirements throughout the life of the contract

Contract Performance n How Do I Monitor Performance (cont. )? Review invoices for contract compliance – Only approve if product/service billed has been delivered per contract – In deliverables based contracts, make sure that milestones have been fully met before remitting payment. – Ensure invoice detail is sufficient for a proper audit. n For a personal service contract, invoices must be submitted as required by statute, KRS 45 A. 695(10).

Contract Performance The contractor must be held accountable to perform at acceptable levels. The quality of work, work schedule/timetable, conflicts, budgets, payments, data, and subcontractors are just a few of the things that should be monitored. Acceptance and rejection requirements should be clearly outlined in the contract. If the contractor has met the obligations, final acceptance/payment should follow.

Contract Performance Payments (per FAP 111 -45 -00) n An agency – shall ensure that adequate funds are available for immediate payment before placing an order; – shall select the appropriate payment method; – shall reference the appropriate contract when making payments in the state’s procurement/ accounting system; – shall process an electronic invoice that will liquidate the encumbrance when payment is authorized, for payments against a document that has been entered into, and has encumbered funds within the state’s procurement/accounting system; – shall retain the official invoice from the vendor for the period of time required by the appropriate document retention schedule.

Contract Performance n n n Payments (cont. ) An agency make payments using a Procurement Card – if exercising small purchase authority – if specifically authorized in the terms of the contract All bills shall be paid within thirty (30) working days of receipt of goods and services or a vendor's invoice and acceptance. Per KRS 45. 454 Penalty for late payment – An interest penalty of 1% per month after thirty (30) working days following the receipt of the goods or services or vendor's invoice by a purchasing agency.

Contract Performance THE BUCK STOPS HERE!! The contract manager is the agency’s front line resource to ensure proper performance and that we are paying for what was required in the contract.

CONTRACT MODIFICATIONS

TYPES OF CONTRACT MODIFICATIONS Contract modifications are generally one of two types: n Administrative modifications – Example - change in source of funding – Changes which do not affect the terms related to vendor performance n Substantive modifications – Example – Changes in scope, quantity, etc. – These changes do affect the vendor and therefore require their approval.

CONTRACT MODIFICATIONS Contract Modifications are governed by statutes, regulations, and policies and procedures: n n n KRS 45 A. 201(1) Issuance of regulations concerning modification and termination of contracts by Commonwealth 200 KAR 5: 311 Contract modifications FAP 111 -11 -00 Modification of Contracts

CONTRACT MODIFICATIONS n n n A Modification shall be used to make corrections or changes to a contract. A Modification shall not be used to initiate a major change outside the original scope of the contract. For Finance issued contracts, a modification shall not be permitted unless issued by the Finance Cabinet. – Agency or vendor can request modification with supporting documentation.

CONTRACT MODIFICATIONS • • • An increase in quantity of goods in excess of ten (10) percent shall not be permitted unless authorized in the Solicitation, and Unit price increases shall not be permitted except as authorized by the solicitation. A Modification shall not be used to increase the dollar amount of a contract established under an agency’s small purchase authority to an amount exceeding the small purchase authority limit.

CONTRACT MODIFICATIONS n Modification to a Personal Service Contract shall be processed in the same manner as the original contract in the state’s procurement system. – agree to increase or decrease funds, – revise the scope of work, – extend the time for performance within the current biennium, or – any other change.

CONTRACT MODIFICATIONS n All contract modifications are amendments to contracts and thus become part of the contract. n All contract modifications must be executed by the buyer or purchasing officer. n Using agencies may make requests for modifications to the buyer. n EO 1 modification must be made if the originally approved dollar amount is exceeded by more than 15%.

CONTRACT MODIFICATIONS n Contract modifications should be within the scope of the solicitation and the existing contract – Must be consistent with the procurement method

REGULATION FOR DISCIPLINARY ACTION Disciplinary action for failure to perform n Failure to post bid or performance bonds, as required by a solicitation; n Substitution of commodities; n Failure to comply with the terms and conditions of a solicitation or contract, – including failure to complete performance within the time specified in the contract; n Failure to replace inferior or defective materials, supplies or equipment

REGULATION FOR DISCIPLINARY ACTION n n n Refusal to accept a contract awarded pursuant to the terms of a solicitation; Falsifying invoices, or making false representations to any state agency or official, about any payment under a contract; Collusion; Failure to report, or to pay the Kentucky Department of Revenue any sales or use taxes; Failure to comply with the prevailing wage law requirements.

REGULATION FOR DISCIPLINARY ACTION n n No purchase shall be made by any state agency from a bidder or contractor who has been suspended from bidding. All state agencies shall be promptly informed about bidders or contractors suspended from bidding.

CONTRACT TERMINATION

200 KAR 5: 31. TERMINATION OF CONTRACTS Any contractor who is determined to be in breach of any of the terms and conditions of a contract with the Commonwealth of Kentucky, shall be declared in default and the contract may be terminated. Contracts may be terminated for: – default by the contractor – the convenience of the Commonwealth, – non-appropriation of funds

200 KAR 5: 312. Termination for Default The Commonwealth may terminate a contract because of the contractor’s failure to perform its contractual duties. This can include: – Failure to perform the contract according to its terms, conditions and specifications; – Failure to make delivery within the time specified; – Late payment or nonpayment of bills for labor, materials, supplies, or equipment furnished in connection with a contract for construction services; – Failure to diligently advance the work under a contract for construction services; – The filing of a bankruptcy petition by or against the contractor; or – Actions that endanger the health, safety or welfare of the Commonwealth or its citizens.

200 KAR 5: 312. Termination for Default The Commonwealth shall not be liable for any further payment to a contractor under a contract terminated for the contractor's default after the date of termination.

200 KAR 5: 312. Termination for Convenience The Commonwealth may terminate a contract for convenience if it has been determined that termination will be in the Commonwealth's best interests. – The Commonwealth shall provide the contractor thirty (30) calendar days written notice of termination of the contract. – the contractor shall have the burden of establishing the amount of compensation to which the contractor believes he is entitled. – the purchasing officer may negotiate a settlement with the contractor according to terms deemed just and equitable by the purchasing agency. – the settlement shall be subject to the prior approval of the Secretary of the Finance and Administration Cabinet, or designee.

200 KAR 5: 312. Termination for Convenience Payment – Payment of the sum agreed to in settlement of a contract terminated for convenience of the Commonwealth shall be made from the same source of funds or account as the original contract. – The Commonwealth shall not pay interest on the amount due under the settlement.

200 KAR 5: 312. Funding Out Provision The Commonwealth may terminate a contract if funds are not appropriated to the contracting agency or are not otherwise available for the purpose of making payments without incurring any obligation for payment after the date of termination, regardless of the terms of the contract. The contracting agency shall provide the contractor thirty (30) calendar days written notice of termination of the contract.

Documentation

WHAT SHOULD BE KEPT? A contract manager’s file should contain the contract, any amendments, and all reports, complaints, and correspondence materially related to the contract.

DOCUMENT, DOCUMENT! It is impossible to overstate the importance of documenting activity during the life of the contract! It is critical in the resolution of disputes or claims! Any staff who deals with the vendor should maintain records of contract activity, and note problems or unusual occurrences. You will rely heavily on the documentation to deal with protests and legal disputes, answer open record requests, handle vendor complaints/cancel contracts for failure to perform, etc.

WHAT SHOULD I DOCUMENT? Regardless of how small or insignificant the matter may seem, problems tend to snowball and can get out of hand. You should: – keep copies of written correspondence and e-mails with the vendor – document telephone conversations with the vendor (date, time, vendor representative’s name) – briefly document meetings with vendor representatives

RETENTION OF PROCUREMENT DOCUMENTS Files and Records – General n n Each agency shall maintain records necessary to support each purchasing transaction. See FAP 111 -28 -00 for additional information.

QUESTIONS & ANSWERS SESSION ? ? ? ? ?