FAR Requirements for Scanned Documents
Q. We scan all of our vendor records but a DCAA auditor has told us they may not be acceptable as source documents unless certain conditions are met. What do the regulations say about this?
A. The regulation is short and sweet. FAR 4.703(d) states three conditions must be met: (1) scanned records must preserve accurate images including signatures and graphics (2) an effective index system is in place to permit timely and convenient access to scanned documents and (3) original records are retained for one year after imaging to permit periodic validation of the imaging system. However, be aware that DCAA auditors may and often do seek to impose additional “internal control” requirements (e.g. written procedures, periodic internal and external audits, easy access to records during an audit) to accept a scanning system. We usually recommend meeting with DCAA to determine objections ASAP.
