Year-end awards often start performance quickly, and the operational work of staffing, kickoff and first deliverables can crowd out the compliance setup a new contract also requires. Several obligations begin at award or within days or weeks of it, and missing them early can create problems that last for the life of the contract. This checklist covers items that commonly apply. Your contract’s clauses control, so read them and talk to a qualified professional about anything unclear.
Week one: read, list and assign
- Read every clause in the contract, including those incorporated by reference, and list each recurring obligation with its deadline.
- Identify the contracting officer, the contracting officer’s representative and the payment office, and confirm how each prefers to communicate.
- Set up a contract file that keeps the award, modifications, correspondence and deliverables together.
- If the contract requires written notice that insurance has been obtained before work begins, send it.
- Confirm that your SAM.gov registration, including banking information, is current, since payment depends on it.
Employees and workplace notices
- If the contract includes the E-Verify clause, enroll if you have not already, and note the clause’s deadlines for verifying new hires and employees assigned to the contract.
- Inform employees in writing of their whistleblower rights and protections, as the contractor employee whistleblower clause requires.
- Display any required fraud hotline posters, which apply to larger contracts.
- On covered service contracts, give employees or post the applicable wage determination and the required notice of employee rights, and confirm that pay and fringe benefits meet the determination.
- Brief staff on the policy against trafficking in persons and on your firm’s ethics standards.
Subcontracts and reporting
Prime contractors are responsible for flowing required clauses to their subcontractors, so this work belongs early, before subcontractors start.
- Execute subcontracts with the flowdown clauses the prime contract requires before subcontractors begin work.
- Calendar first-tier subcontract reporting under the federal funding transparency clause, which requires qualifying subcontracts to be reported after award.
- If you hold a small business subcontracting plan, set up the data you will need for your reports.
- On set-aside contracts, set up a way to track compliance with the limitations on subcontracting from the first invoice.
Systems, security and records
- Register in the invoicing system the contract specifies, and submit the first invoice early enough to fix problems.
- Start background investigations, badging and system access requests for staff who need them.
- Confirm that information systems handling federal contract information or controlled unclassified information meet the contract’s security requirements, and know the incident reporting deadlines that apply.
- Review the contract’s records clauses and set retention practices for timesheets, invoices and correspondence.
- Set reminders for deliverables, reports and option exercise dates.
Assign each item an owner and a date, and review the list with your program manager at the end of the first month. Items still open after thirty days usually point to a missing process, not just a missed task. Clause texts are available at acquisition.gov, and your SAM.gov record is at sam.gov.