2.  Wide Area WorkFlow Payment Instructions Clause

Comment: Three comments addressed paragraph (f)(1) of the clause. One respondent identified that a listed document type is not an allowable document for their office, and that there is a possible conflict in language between this paragraph and the note that follows.

Another respondent provided two comments. First, issues were noted with regard to possible scenarios resulting from ambiguous terminology and a lack of identified procedures to address said scenarios. Second, the respondent is unsure the reader will understand the intended use of the note following the paragraph, and requested the note be clarified as to its purpose and intended use.

Response: Regarding the concern of allowable document types, applicable instructions to preclude possible conflicts have been incorporated into the WAWF Web site. A link to the Web site is included in the DFARS clause and in the Procedures Guidance and Information (PGI) text. In addition, since it is the contracting officer who inserts the document type into the clause, there should be no resultant issue. Therefore, no change is made to the language of the rule as a result of this comment.

In response to the concern regarding possible scenarios resulting from ambiguous terminology of the text, the language in question is deleted, leaving a clear statement. Likewise, deletion of this text served to resolve the comment concerning the intended use of the note following the paragraph.

Comment: Two respondents expressed concern with the Routing Data Table at paragraph (f)(3). The respondents indicated that the table may increase the workload of contracting personnel and increase the opportunity for error and inconsistency. Also, the table may not account for all circumstances.

Response: The Routing Data Table along with the instructions for the contracting officer to complete the table is retained in the final rule; however, several of the respondents' suggestions, which clarified a number of table elements, are incorporated into the final rule. DoD retained the Routing Data Table and instructions after considering the following:

(1)  The possible variation in contract formats and types;

(2)  the absence of a more acceptable place to identify the local processing office in existing contracts; and (3) in order to increase the ease of use and facilitate contractor compliance.

Comment: One respondent recommended revised language for paragraph (f)(4) to strengthen the rule in consideration of future audits.

Response: The data requirements for documentation to be submitted with specific actions are well defined elsewhere in the regulations (e.g. DFARS Appendix F). Repeating those requirements again in the clause would create redundancy and introduce the possibility of conflict between updates to Appendix F and the clause language.

Comment: Two respondents observed that the clause language for paragraph (g), Payment request follow-up, is not compatible with current systems and does not provide complete information regarding availability of invoice status.

Response: The paragraph (g) clause text is deleted since the capability discussed is now provided for in WAWF. Therefore, inclusion of the paragraph (g) text is not necessary.

Comment: Two respondents noted that paragraph (h), WAWF point of contact, may not be appropriately included; or if included, a better point of contact could be provided.

Response: Former paragraph (h), which is now paragraph (g) in the final rule, is updated to include subparagraphs so that an additional point of contact for technical issues, the WAWF helpdesk, is also listed.

Comment: One respondent identified a disparity between language in the existing clause at 252.232.7003, Electronic Submission of Payment Requests and Receiving Reports, paragraph (b), and the proposed clause paragraph (b) regarding "preferred method" versus "contractor shall".

Response: WAWF is the DoD system to electronically process payment requests and receiving reports, therefore the word "preferred" was deleted in the final rule. Further, in this same paragraph (b); language regarding alternate invoicing methods as agreed to by the parties is also deleted. The remaining language demonstrates DoD's effort to meet the intent of the E-Government Act and the Paperwork Reduction Act in minimizing the number of ways contractors must interact with the Government.