a. The Standard Compliance Evaluation Report. The SCER documents the scope, progress and results of an on-site review.86 It also includes notes confirming that a contractor met its obligations or describing any problem areas the CO identified during the desk audit, on-site review, and off-site analysis. A CO may not be able to complete the desk audit portion of the SCER because the quality of the desk audit data is inadequate or was insufficient. In that situation, the CO’s initial task during the on-site review is to complete the desk audit portion of the SCER. You will find a copy of the SCER and instructions for completing it in Appendices A-1 SCER and A-2 SCER Instructions.
With a full understanding of the contractor’s employment practices and affirmative action efforts, a CO may identify new problems or find that the contractor resolved previously identified problems. COs must describe problems identified during the on-site review and record any recommendations for corrective actions to resolve problems.
b. Obtaining and Maintaining Records. All communications and information COs gather during the compliance evaluation must remain in the case file. Examples of information or data a CO might gather are data and record submissions by the contractor; information gathered from other sources such as applicants and employees; and interviews with contractor officials, employees and others. This includes all information obtained during the on-site review. In addition, COs must document their activities and communications in connection with the on-site review in the compliance evaluation or Case Chronology Log.87
These are several of the general principles for properly maintaining records:
- Every document collected during the review, even if it does not support the ultimate finding, is included in the case file. These documents include those in both paper and electronic formats.
- All email and other written communications must be dated, identify the individuals participating in the communication, and accurately reflect any agreed commitments. For example, the emails in a CO and contractor email exchange discussing possible dates for the on-site review would reflect the CO’s name and position, the name and position of the contractor’s representative, the dates proposed and the dates for the on-site review that were agreed upon.
- Original documents submitted by contractors or otherwise obtained by COs must not be altered. Alterations, including notes made by a CO, should be made on working copies.
- Interview statements, whether obtained by a CO in person or by telephone, must remain in the case file. These statements must include the name and position of the person conducting the interview, the name of the person interviewed and his or her title or position, the date and time of the interview, and the location of the interview. COs must also note if other people were present during the interview such as the legal counsel or a personal representative. Interviewees should review and sign the CO’s interview notes and typed statement indicating that they are accurate. Section 2M of this chapter provides specific information on interviews.
- Information obtained during interviews and a CO’s observations must be reduced to writing as soon as feasible. The CO must type handwritten notes, using MS Word, before placing them in the case file.
- Supporting evidence must be in a clearly labeled section of the case file. Supporting evidence may include the CO’s notes, worksheets, contractor data and any other material related to specific problem areas identified by the CO.
86. COs will not use all the pages of the SCER in every evaluation. Rather, which sections of the SCER are appropriate to each review will depend on the type of compliance evaluation. However, COs must complete all relevant SCER pages and sections.
87. See FCCM 1B01 – Preparation and Maintenance of the Case Chronology Log; 1B02 – Creation and Maintenance of the Case File and Figure F-2 Case Chronology Log for additional information regarding the case file and Case Chronology Log.