31.  Policies and Procedures

Comment: The proposed rule contains inconsistent, ill-defined system criteria for policies and procedures. The requirement for policies and/or procedures is the same for all business systems and, therefore, the proposed rule should be consistent by using the terms "policies and procedures" in all sections defining system criteria. The proposed rule should be revised to specify that a business system's criteria for policies and procedures should be in writing.

Response: System criteria are consistent with well-established Government practices and procedures for assessing the contractor business systems. For some business systems, the DFARS language supplements established FAR criteria, while other business systems criteria are established or revised by this interim rule. Therefore, it would be inappropriate to attempt to force incorrect terminology into business systems criteria for the sake of consistency. The systems criteria contained in the business systems clauses have been used for many years by Government personnel to assess the reliability and accuracy of management information produced by the applicable system.