OCR Government Contracts: Standard Forms and Modifications

To OCR government contracts from a scanned federal file, convert the award as one document and each modification as its own, in number order. Proofread the form cover pages block by block, export the line item schedule as a table, and list every clause the contract cites by number and date, because that text is not in the scan.

A federal contract is built to a pattern set by regulation, and the pattern tells you where each fact should sit. This post covers handling the pages. It does not say what any clause means for your client.

What does a scanned federal contract file contain?

A scanned federal contract file holds the award document, with a form cover page, a schedule of line items, a statement of work, a clause section and attachments, followed by a run of modifications. Solicitation papers, correspondence and invoices may be scanned into the same PDF, so sort the pages before you convert anything.

Sorting pre-award pages from the contract

The same form number can appear on a page issued before award and on a page issued after it. Standard Form 30 is titled "Amendment of Solicitation/Modification of Contract", and FAR 53.243 prescribes it both for amending invitations for bids and for modifying contracts. Read the blocks on each SF 30 in your scan to see which of the two it is, and file solicitation amendments apart from contract modifications.

A copy that an agency released with redactions

A contract obtained through a records request can arrive with boxes over unit prices or names. The federal Freedom of Information Act lists, at 5 U.S.C. 552(b)(4), "trade secrets and commercial or financial information obtained from a person and privileged or confidential" among the matters the statute does not apply to. That is federal law; a state or local contract is released under that state's own records law. For conversion, a covered cell is a gap you record, never a blank you fill. The post on OCR of documents someone else redacted gives a notation for the gaps, and the post on how to redact a scanned contract covers the reverse task, when your side is the one removing prices.

Copy the contract number, the award date, and the contractor's legal name from the cover of the government contract. Read each price a modification changes, using the page image. If the clause list names a remedy or a breach of contract provision only by a number, write that number and the date printed beside it.

How is a federal contract organized under the uniform contract format?

The uniform contract format divides a contract into lettered sections grouped in parts. FAR 15.204-1(a) says contracting officers "shall prepare solicitations and resulting contracts using the uniform contract format outlined in Table 15-1". Find the section letters in your scan and you have the document's skeleton.

Table 15-1 of that subsection reads as follows.

Why sections K, L and M may be absent from the contract

A file that stops at Section J is not necessarily short of pages. FAR 15.204-1(b) says that upon award, contracting officers "shall not physically include Part IV in the resulting contract, but shall retain it in the contract file." If your scan of the awarded contract has no Sections K, L and M, record that and check whether the solicitation is in the file as a separate document. If your scan does carry them, you may be holding the solicitation, or a contract with the solicitation bound in.

Contracts that do not follow the lettered sections

The lettered format is not the only one. Subsection 15.204-1 is in Part 15 of the regulation, so read your own contract before assuming the lettered format applies. For commercial products and commercial services, FAR 12.303 sets out a different assembly: Standard Form 1449, continuations of its blocks, the contract clauses, then "any contract documents, exhibits or attachments". A scan built that way has no Section B or Section I to search for. Its line items continue from a block on the form, and its clauses are the ones 12.303(c) lists, beginning with 52.212-4 by reference.

Using the section letters during conversion

Section letters make good split points and good file names. Search the converted text for "SECTION B", "SECTION C" and so on, note the scan page where each begins, and enter the page ranges in an index. Where a letter is missing between two that are present, look at the image: a heading in a ruled box or in reversed type can be dropped by recognition while the section itself is all there. The index also tells a later reader where to look. A question about delivery dates goes to Section F, and a question about who pays the invoices goes to Section G.

Standard form cover pages and their numbered blocks

A standard form cover page is a grid of numbered blocks, each with a small printed label and a typed or stamped entry. Recognition can return the labels and the entries as two separate runs of text. Treat the page as a form: read each entry against its block on the image and record block number, label and entry together.

The forms you may meet, with the regulation section that names each:

Those sections name more forms than this, and agencies use forms of their own, so take the form number and edition from the corner or footer of your page. Do not assume an edition. FAR 53.214 and FAR 53.215-1 cite different revision dates for the SF 26 and the SF 33, which is a good reason to copy the edition from the paper in front of you.

What goes wrong on a block form

• Label and entry part company. The text may list twenty labels and then twenty entries. The method for keeping each answer beside its field label applies to these forms without change.
• Small codes sit in small boxes. Contract numbers, requisition numbers, activity codes and accounting strings are long runs of letters and digits with no dictionary word to steady them. Read each one character by character.
• Check boxes carry choices. A form may use a row of boxes to show what kind of action it records. Look at the image for which box is marked. Converted text is not a safe guide to that.
• Signatures and dates are ink. The contracting officer's signature block and the contractor's are marks on the image. Record the printed name, the title and the date beside each, and note a block that is empty.
• Stamps land on top of entries. A received stamp or a distribution stamp over a block can garble both.

Blocks the regulation itself points to

A few block numbers are stated in the regulation, which helps when a scan is cropped or faint. FAR 12.303(b) lists continuations of SF 1449 blocks, among them block 19 for line item numbers and block 20 for the schedule of supplies or services. FAR 53.214(a) says of the SF 26 that "Block 18 may only be used for sealed-bid procurements." FAR 53.243 refers to Item 3 of the SF 30 instructions as the effective date. For every other block, the label printed on your form is the authority.

A cover page record

For each form, fill in a short record and keep it with the converted file. This one is for a fictional award to Tidewater Calibration Services, Inc.

The page count on the form gives you a completeness test at no cost. If the form says 48 pages and the award portion of your scan has 44, find out why before converting further.

Clauses incorporated by reference that never appear in the scan

A federal contract can make a clause part of the deal by listing its number, title and date and nothing more. The clause text is then nowhere in the scan, and no conversion will produce it. Your job is to capture the list exactly and fetch the text from the regulation.

The clause that does this is short. FAR 52.252-2, Clauses Incorporated By Reference (Feb 1998), begins: "This contract incorporates one or more clauses by reference, with the same force and effect as if they were given in full text. Upon request, the Contracting Officer will make their full text available." It then leaves a blank for one or more internet addresses where the text can be read.

Two more sections explain what the list in your scan should contain.

• FAR 52.103(a) says a FAR provision or clause used without deviation, "whether it is incorporated by reference or in full text", "shall be identified by number, title, and date." It adds that when a clause is used with an authorized deviation the contracting officer inserts "(DEVIATION)" after the date.
• FAR 52.102(b) says the contracting officer, "upon request, shall provide the full text of any provision or clause incorporated by reference."

Building the clause list

1. Find the clause section in the converted text. Under the lettered format it is Section I, though clauses also turn up in other sections and in attachments.
2. Copy every line of the list into a spreadsheet with three columns: number, title, date.
3. Read each number and date against the image. A clause number such as 52.212-4 is all digits and punctuation, and the date is a month and year in a narrow column. A single wrong digit sends you to a different clause.
4. Mark any entry that carries "(DEVIATION)" or the name of an agency supplement, since its text is not the standard one.
5. Copy the internet address written into the 52.252-2 blank, if the scan shows one.
6. For each row, pull the clause text and file it with the contract.

Fill-ins hiding under a clause title

A clause listed by title only can still hold facts specific to your contract. FAR 52.104(d) tells the contracting officer, when completing blanks in a clause incorporated by reference, to "insert the fill-in information directly below the title of the provision or clause". So a line or two of indented text under a clause title in your scan is not clutter. It may be a number of days, a percentage or an address that the clause leaves open. Add a fourth column to the list for fill-in text and its scan page.

The date is part of the citation

Clauses are revised, and the list gives a date for each one. The text you need is the edition with the date your contract cites, which may differ from the edition published today. When the dated edition is not the current one, say so in your list and record where you obtained the text, or ask the contracting officer for it in reliance on the sentence quoted from 52.252-2. Do not paste current text beside an old date without a note.

Converting an award and its modifications in order

Convert the award first as a single document, then each modification as its own file in number order, and keep a log that states what each modification changed. Do not merge them into one text. The award and every modification are separate signed or issued documents, and a later reader must be able to see each one alone.

1. Inventory the scan. List every form cover page with its form number, its document or modification number, its dates and its page range.
2. Look for gaps in the numbering. If your scan holds modifications numbered one, two and four, ask for the third before you rely on the set.
3. Split the PDF at each cover page. Continuation sheets stay with the form they continue. FAR 43.301(b) allows "a blank sheet of paper" as a continuation sheet, so a plain page after an SF 30 may belong to it.
4. Convert the award. Proofread the cover page blocks, index the lettered sections, export the schedule as a table and build the clause list.
5. Convert each modification. Proofread its cover page and read the description of the change in full against the image.
6. Log each modification. Record the kind of modification, its effective date, who signed, and which section, line item or clause it touches.
7. Carry changes into your working tables. Update the line item workbook and the clause list with a new dated row for each change, leaving the original row in place.

Unilateral and bilateral, as the regulation uses the words

FAR 43.103 describes two types. A bilateral modification "is a contract modification that is signed by the contractor and the contracting officer." A unilateral modification "is a contract modification that is signed only by the contracting officer." For conversion, that means one signature on a modification is not by itself a sign of a missing page. Record which signature blocks are filled, and let the lawyer decide what follows from it.

Which date goes in the log

A modification can show a signing date and an effective date that differ. FAR 43.101 defines the effective date by the kind of action: for a solicitation amendment, change order or administrative change it "shall be the issue date", and for a supplemental agreement it "shall be the date agreed upon by the contracting parties." Log both dates as written on the form and sort by effective date, with the modification number as the tie-breaker.

Working out the text of the contract as changed is a further step, and the post on building a conformed copy of a contract sets out that method. Purchase orders between private companies raise a different problem, with terms printed on the back of the form, and the post on OCR of purchase order terms deals with it.

Line item tables: getting quantities and prices into a spreadsheet

Export the schedule of supplies or services as a table, one row per line item or subline item, and recalculate every extended price. The schedule is where the money is, and its digits get no help from context, so check each row against the page image before anyone totals it.

FAR 4.1001 says procurement instruments "shall identify the supplies or services to be acquired as separately identified line items and, as needed, subline items." FAR 4.1005-1(a) lists the data each one includes at a minimum, starting with its number, a description, a product or service code and an accounting classification citation. Paragraph (a)(5) adds, for fixed-price line items, unit of measure, quantity, unit price and total price, and for cost-reimbursement line items, unit of measure, quantity, estimated cost, fee if any, and total estimated cost plus any fee. Those lists give you the column headings for the workbook.

Columns for the workbook

Problems peculiar to federal schedules

Subline items nest under a line item. FAR 4.1001(b) says that if a line item has deliverable subline items, "the line item is informational." A total that adds a parent row to its own subline rows counts the same money twice. Mark informational rows and leave them out of sums.

The schedule runs across continuation sheets. Each sheet may repeat the column headings and carry a page header. Remove the repeated headings after export, and confirm that the last row of one sheet and the first row of the next are separate items and not one item split in two.

Option items are priced but not yet ordered. A schedule can list base and option line items side by side. Add a column for whether a modification has exercised each option, and fill it from the modification log.

Descriptions wrap over several lines. A long description can push a quantity or price onto the wrong row in the export. Count the rows on the image and in the sheet.

Modifications restate part of the schedule. When a modification adds or reprices a line item, enter a new row with the modification number as its source. Keep the earlier row and mark it superseded, so the workbook shows the history.

The general method for fee and price tables is in the post on converting a scanned schedule to Excel. If you use Schema Law for the conversion, its Excel export puts each table on its own sheet and the rest of the text on another, and its CSV export carries the document's tables; the list of export formats describes each one. The site says recognition is strongest on clean print, and that nothing marks a passage as uncertain, so the recalculation is the test. Aim for a workbook in which quantity times unit price equals the total on every row and the rows sum to the amount on the cover page. Where either test fails, the page image shows whether recognition or the contract itself is the source of the difference.