IN THE FIELD

Project Management

Filling the Gaps

Compliance on government & specialty jobs depends on a connected project record

BY TARA ANDERSON

An April 2026 federal audit reviewed nine Infrastructure Investment and Jobs Act (IIJA)-funded Federal Aviation Administration (FAA) facility and equipment contracts. Five were missing one or more required Buy American-related clauses, representing about $272.7 million in IIJA funds. FAA also used foreign products in three contracts and had problems with the waiver process. Those three represented $115.9 million in IIJA funding. One week later, two senators introduced a bill that would require agencies to report annually on their implementation of the Build America, Buy America Act (BABA).

That audit is aviation-specific, but the records lesson isn’t. It didn’t examine contractor closeout files or whether installed products matched approved submittals. It showed how missing clauses, weak waiver controls and incomplete data can undermine a compliance record. On government and specialty work, the same operational question applies: Can you show what requirement applied, what was approved, what changed and what was installed?

I look at this through the lens of project information management, because that’s where compliance becomes provable. In my experience, documentation gaps often begin with a record that exists somewhere but isn’t connected to the decision it supports. The certification is in an email. The reason for an approval lives in someone’s memory. The change order was never tied back to the submittal it modified. Individually, none of these gaps looks like a crisis. Together, they create the kind of record an auditor may question.

Government Work Means Proving Your Materials, Not Just Installing Them

For infrastructure projects receiving federal financial assistance, BABA generally requires covered iron, steel, manufactured products and construction materials incorporated into the work to be produced in the U.S. A manufactured product must satisfy the applicable domestic content requirements, which for many federal procurements currently include a threshold of more than 55% domestic component cost, unless another applicable standard applies. The preference must flow into applicable subawards, contracts and purchase orders, so a supplier’s sourcing decision can become a project compliance issue.

Most teams can explain the rule. Where they struggle is proving they followed it. The specification identifies the requirement. The submittal identifies the proposed product. A manufacturer certification or mill record may help document origin. A request for information (RFI) records a question or proposed change. A change order may approve a substitution under the contract. When a BABA waiver is required, the recipient requests it and the federal agency issues it. Every record can be correct and still leave a gap when the records live in five different places.

Capture the certification during procurement and submittal review. Connect it to the submittal, any related RFI or change, the applicable waiver and the record of what was installed.

Retention adds another layer. Federal Acquisition Regulation Subpart 4.7 applies to contracts containing specified audit and records clauses. For those contracts, records generally must remain available for three years after final payment or for an applicable record-specific period, whichever ends first. Under federal financial assistance, recipients and subrecipients generally retain award records for three years after submitting the final financial report. Unresolved claims, litigation, audit findings and contract terms can extend those periods. Follow the requirements passed down in your own contracts and purchase orders, read the actual terms instead of guessing and set the retention schedule at kickoff.

Specialty Jobs Stack a Second Rulebook on Top

Government work isn’t the only place this shows up. Healthcare construction often requires an infection control risk assessment and records showing that required controls stayed in place. Historic preservation work may require photographs, drawings, material records and approvals that show conformance with applicable standards. Secured facilities may add access, clearance and chain-of-custody records.

The specific requirements change by project type. The operational need doesn’t: Show what applied, what evidence came in, who reviewed it and which decision it supports. The legal and contractual duties may differ from job to job, but the project information challenge stays the same.

Build the Record While the Work Is Moving, Not After

Fixing this at closeout is too late. Turn every contract or funding requirement into a plain list of evidence you need to keep. Assign an owner and a location for each record type before the first submittal comes in. Capture certifications the moment a submittal gets approved, not when the project wraps. Link submittals, RFIs, transmittals, changes and inspections to each other so one search pulls the whole story, instead of five people’s inboxes. Before handover, give someone outside the project team the name of one installed material. Measure how long it takes them to find its full history.

That last test tells you the truth. If it takes more than a few minutes, you likely have a retrieval gap that an outside reviewer will see too.

The FAA audit isn’t proof that every contractor is failing. It’s a reminder that public and regulated work puts added pressure on the project record. The contractors best prepared for review know the requirements and can produce the connected record showing how the team met them.

That’s project information management in practice: every requirement connected to the evidence, review and decision behind it.

Note: This article is general information, not legal advice. Requirements vary by funding source, agency, award and contract.