Yes. With the proviso that it's not for us to provide a legal opinion, what I would say is that the Financial Administration Act certification, which requires a delegated official to release payment, would basically be seen by our office as that person saying that they got the services—or the goods, in the case of a goods contract—that were supposed to be provided. That's a problem when there isn't a paper trail: The government is in a tough spot going after a person for whom they've authorized payment and certified that the goods and services were received.
Our message to the public service is make sure that you document your files when you sign off on the release of public funds to a contractor.