RGCI - Department of Health and Human Services Proposes Transition to New Payment Platform

On October 4, 2021, the Department of Health and Human Services (HHS) proposed an amendment to its Federal Acquisition Regulation (FAR) Supplement to support the HHS Electronic Invoicing Implementation Project and HHS’s transition to the Department of the Treasury’s Invoice Processing Platform. This rule would add HHS Acquisition Regulation (HHSAR) Subpart 332.70 (which is comprised of HHSAR 332.7000 through 332.7003) Electronic Submission and Processing of Payment Requests to provide policies and procedures for these requests.

Key Takeaways from Proposed Rule

A “payment request”, as defined in the proposed subpart, is a bill, voucher, invoice, or request for contract financing payment with associated supporting documentation. The applicable payment clause must be included in the contract and the payment request must comply with the requirements in FAR 32.905(b) Content of Invoices.

Contracts must require electronic submission of payment requests through the inclusion of HHSAR 352.232-71, Electronic submission of payment requests, unless purchases are made with a Government-wide commercial purchase card and some classified contracts when electronic submission and processing could compromise classified information or national security.

The contracting officer can require another method for submitting a payment request, but they must make a written determination that:

  • HHS is unable to receive electronic payment requests or provide acceptance electronically;
  • The contractor has demonstrated that electronic submission would be unduly burdensome; or
  • The contractor is in the process of transitioning to electronic submission of payment requests, but needs additional time to complete such transition.

We plan to submit comments and suggest you do the same. Comments on the rule can be submitted through the Federal eRulemaking Portal. Search for “HHSAR 332.70”, select “Comment” and follow the instructions to submit a comment. Comments are due by November 15, 2021.

Redstone GCI is Here to Help

Redstone GCI assists contractors throughout the U.S. and internationally with understanding the Government’s expectations and supporting contractors with submission of payment requests, as well as navigating the Government regulation landscape.

Learn More About Our Accounting & Billing System Compliance Services

Written by Redstone Team

About Redstone GCI

Redstone GCI is a consulting firm focused on fulfilling the needs of government contractors in all areas of compliance. With a singular mission to help contractors through the multiple layers of “red tape,” we allow contractors to focus on what they do best – support their mission with the U.S. Government. We are home to a group of consultants made up of GovCon industry professionals, CPAs, attorneys, and retired government audit and acquisition professionals.

Our focus and knowledge of audit and compliance functions administered by DCAA and DCMA will always be at the heart of what we do. However, for the past decade, we’ve strategically grown to support other areas of the government contractor back-office with that same level of focus and expertise. We’ve added expertise in contracts management, subcontract administration, proposal pricing, various software systems, HR and employment law, property administration, manufacturing, data analytics/reporting, Grant specialists, M&A, and many other areas. When we see a trend in the needs of contractors, we act to ensure we can provide the best expertise in the market to fulfill those needs.

One thing our clients can be certain of is that with the Redstone GCI Team in your corner, there is no problem too big and no issue too technical for our team to tackle.

Topics: Compliant Accounting Infrastructure, Government Regulations, Federal Acquisition Regulation (FAR)