How complete is your contract file?  Do you have information on your company’s current discounting practices?  How about country of origin information for Trade Agreements Act (TAA) compliance?  While maintaining a complete contract file may be a tedious undertaking, incomplete records can cost your company a lot.   A recent US District Court ruling in United States ex rel. Louis Scutellaro v. Capitol Supply, Inc., found that the company’s failure to retain country of origin documentation for its GSA Schedule items entitled the whistleblower and the government to an adverse inference that the defendant did not comply with the TAA.  If not successfully appealed, this ruling could end up costing Capitol Supply millions.  It didn’t need to be TAA related, either.   Poor record keeping that leads to Price Reductions Clause or Services Contract Act violations are just two of potentially many more examples of how your firm can get in real trouble.  Imagine what type of record or documentation solution your company could implement for a fraction of the amount of fines, penalties, attorney’s fees, and other costs the firm in this specific case is facing.  One best practice may be to implement an annual stand-down day to review your contract file and make sure you have what you need to survive an audit or whistleblower action.  If “the dog ate my homework” didn’t work in 4^th grade, it certainly doesn’t work in government contracting.