DECISION
Transamerica Insurance Corporation appeals from a bench ruling of the United States Claims Court which granted the United States’ motion to dismiss Trans-america’s complaint for lack of subject matter jurisdiction. The Claims Court found that the contractor’s submissions did not *1574 constitute a claim under the Contract Disputes Act of 1978 (CDA), 41 U.S.C. § 601, because they did not request a final decision from the contracting officer. In the alternative, the Claims Court held that the contractor’s claim certification was fatally flawed because it was unduly qualified. This court reverses and remands.
BACKGROUND
On September 15, 1987, the United States Army Corps of Engineers (Government) entered a contract with contractor Bodenhamer Building Corporation (BBC) for the construction of Bowley Elementary School at Fort Bragg, North Carolina, for the contract price of $3,804,000. On October 6, 1987, Bodenhamer entered into a subcontract with Stroup Sheet Metal Works for specified roofing work under the contract. Transamerica Insurance Corp., acting as surety, issued payment and performance bonding for the Bowley project.
Construction under the roofing subcontract began in late summer 1988 at which time Stroup discovered a disparity between the actual requirements of the subcontract and the roof plan on which it had based its bid and so informed BBC. In an August 2, 1988 letter, BBC notified the Area Engineer at Fort Bragg of the specification discrepancy, informing him that the roof plan was incorrectly scaled and that in actuality there was “approximately two times the square footage shown on the roof plan.” BBC further notified the Government that this discrepancy would require additional material, labor and time, with delays affecting the completion date, and that as of 3 p.m. on August 2, Stroup’s roofing operation had been stopped until direction could be received on how to proceed.
Responding to BBC in a letter dated August 3, 1988, the contracting officer’s authorized representative stated that: (1) as the contractor, BBC was responsible for and should have reviewed the drawings and that “approval by the contracting officer shall not relieve the contractor from responsibility for any errors or omissions in such drawings;” (2) the contractor should have notified the contracting officer of these discrepancies earlier; (3) drawings which purport to be done to scale are not necessarily binding; (4) “the Contractor shall compare all drawings and verify the figures before laying out the work and will be responsible for any errors which might have been avoided thereby;” and (5) BBC was requested to submit a written corrective plan of action by August 10, 1988.
On August 9, 1988, BBC drafted two letters, one to its subcontractor Stroup and one to the contracting officer. The Stroup letter notified the subcontractor of the Government’s denial of responsibility, instructed Stroup to continue to work on the project pending resolution of the claim, and offered to be the “conduit” for an equitable adjustment claim which Stroup could make to the contracting officer. The letter to the contracting officer stated BBC's position that the problem in the specifications arose due to errors in the contract drawings and thus that “this problem is a design error which is the responsibility of the Government and not the Contractor.” BBC further stated, “[w]e can offer no written corrective plan of action inasmuch as we have done nothing wrong which needs to be corrected. ... We recognize your letter as a directive ... which constitutes a constructive change to the Contract. Accordingly, we hereby notify you that we are proceeding as directed by you and reserving all rights granted us under the Contract for an equitable adjustment in the Contract for all additional costs incurred, both direct and indirect, as a result of this design deficiency.”
In an August 26, 1988 letter, Stroup submitted to BBC a request for equitable adjustment of the subcontract, maintaining that the alleged defect in the roofing specifications increased the cost of performance by $241,919. As part of the equitable adjustment request, Stroup included a request for an extension of time for the duration of construction due to the expanded scope of work of 135 days and included a certification signed by Stroup’s president. In a September 1, 1988 letter, BBC submitted Stroup’s claim and request for eq *1575 uitable adjustment to the contracting officer and included a certification executed by BBC’s president.
On or about September 6, 1988, BBC notified the Government of its intention to abandon its contractual obligations and on September 8, 1988, the Government terminated the BBC contract for default. On September 15, 1988, Stroup learned that BBC’s contract was in default and that the surety Transamerica would be taking over the project through completion contractor Sebeo. Thereafter, Transamerica entered a ratification agreement with Stroup for the completion of Stroup’s contractual obligations on the project. On November 7, 1988, Transamerica and the Government entered into a surety takeover agreement under which Transamerica agreed to take over and complete performance of the BBC contract. The agreement provided that the “surety shall have the right to pursue and settle all existing and future claims that arise under this contract.”
On November 25, 1988, Stroup wrote the Chief of the Claims Section of the U.S. Army Corps of Engineers, urging him to make an expeditious decision on the pending equitable adjustment claim which had been submitted on September 1. On February 21, 1989, Stroup talked by telephone with both the Government and the former general contractor in an effort to get a final decision on its claim. After the conversation, on March 8, 1989, Stroup submitted to Transamerica and to the Government a revised cost summary on Form 1411 with a revised claim for equitable adjustment. On March 15, 1989, the contracting officer requested submission of supplemental information, including all cost and pricing data as well as a recertification of the claim by the surety. The contracting officer also required that Transamerica adopt Stroup’s claim as its own “since Stroup does not enjoy privity of contract with the Government” and that if the request for more time was “intended to assert a right to a contract time extension, Stroup and/or Transamerica should submit full justification for the requested time extension.”
. On March 28, 1989, the contracting officer issued a preliminary decision denying the request for equitable adjustment. The decision stated:
The claim is presented as a request for equitable adjustment and the basis of it is not clearly stated.... I acknowledge that the graphic scale provided was erroneous and reliance upon dimensions scaled from that undimensioned schematic plan would have resulted in quantities of the various elements of the roofing system which were substantially less than the quantities actually required to be performed_ Under the circumstances of these bid documents, any reliance upon the Roof Plan for quantities of required work was imprudent and such reliance is at the risk of the bidder. Based on the above, it is my present intent to deny your claim; however, this is not my final decision. I will consider any additional information you may have or meet with you to discuss the claim.
On May 17, 1989, Stroup’s counsel took exception to the contracting officer’s request for a second certification by Trans-america as requested in the March 15 letter. But on May 18, 1989, Transamerica submitted to the Government its certification of Stroup’s claim signed by the Eastern Bond Claims Manager for Trans-america.
On. July 5, 1989, Stroup completed all work required under the subcontract on the Bowley project. On August 8, 1989, Trans-america submitted to the Government a contract pricing proposal cover sheet, revising the equitable adjustment claim upward to $265,549.89 plus interest. On April 13, 1990, the contracting officer issued a unilateral contract modification adjusting the contract price upward by $179,530.25 plus interest, based upon the contracting officer’s determination that the erroneous roof scale constituted a changed condition entitling the contractor to an equitable adjustment of its contract amount. 1 On April 23- *1576 24, 1990, Stroup’s counsel protested the “accord and satisfaction” language of the change order, but after the Government agreed that acceptance of the modification amount did not waive its right to pursue the remainder of equitable adjustment costs on appeal, Transamerica and Stroup agreed to accept the modification as partial payment only.
On October 24, 1990, Transamerica filed a complaint in the Claims Court, seeking a judgment against the Government in the amount of $86,019.64 plus interest (the difference between the amount awarded in the unilateral contract modification and the amount sought as equitable adjustment), reasonable costs and attorney fees and any other relief considered appropriate. On July 12, 1991, the court conducted a status conference which included arguments on jurisdictional issues, and on October 31, 1991, the court conducted a hearing on the Government’s motion to dismiss, at the end of which the Claims Court pronounced its findings and conclusions from the bench, granting the United States’ motion to dismiss for lack of subject matter jurisdiction and finding that Transamerica’s letters (mainly the September 1, 1988 letter but also considering the August 26, 1988 letter) did not constitute a claim under the CDA because they did not request a final decision from the contracting officer. In the alternative, the Claims Court held that certification of the claim was invalid because language in the cover letter submitted with the certification impermissibly qualified it. On November 1, 1991, the complaint was dismissed on the jurisdictional grounds set out in the bench ruling. Transamerica appealed.
DISCUSSION
Standard of Review
“This court reviews Claims Court judgments to determine whether they are ‘incorrect as a matter of law’ or premised on ‘clearly erroneous’ factual determinations.”
Whitney Benefits, Inc. v. United States,
Request for a Contracting Officer’s Final Decision
The main question before this court on appeal is whether the Claims Court erred in holding that BBC’s September 1 submissions did not include a request for a final decision, either express or implied, as the Government alleges it was required to do under the CDA and case law. Transamerica argues that the claim as submitted by BBC to the contracting officer met all the requirements of the CDA and thus conferred jurisdiction on the Claims Court. Section 605(a) of Title 41 U.S.C. states:
All claims by a contractor against the government relating to a contract shall be in writing and shall be submitted to the contracting officer for a decision.
Section 605(a) by requiring submittal of a written claim “for decision” does not of itself add any authority to the argument that there must be an explicit request for a contracting officer’s final decision. The statute’s broad language demonstrates that as long as what the contractor desires by its submissions is a final decision, that prong of the CDA claim test is met.
Besides the little actual guidance the statute provides on this issue, the Government in this case relies on this court’s decision in
Mingus Constructors, Inc. v. United States,
In setting out the aforementioned language, the
Mingus
court cited the Claims Court’s decision in
Hoffman Construction Co. v. United States,
The court believes that in order to establish that a ‘claim’ has been submitted to a contracting officer the relief requested must include an expression of interest in a final decision by the contracting officer. Such a belief is supported by the language in section (c)(iii) of the Disputes Clause which states that a written claim shall be submitted to the contracting officer for decision. See also 41 U.S.C. § 605(a).
As explained above, section 605(a) does not speak authoritatively to the issue sought to be proved by the Claims Court in this case. Furthermore, the citation to Paragon Energy for authority for this “requirement” is also off the mark. While it is true that the Paragon court considered the question of whether the written claim was “submitted to the contracting officer for a decision” under section 605(a), in that case the Court of Claims found that because the “letter expressed Paragon’s interest in a ‘final decision’ with regard to its ‘request for contract reformation,’ ” that sufficed to meet the standard of section 605(a). However, the Paragon court, in no way set up such a requirement under section 605(a). It simply found that the particular factual showing in its case met the articulated statutory standard. Thus, the Claims Court’s decision in Hoffman does not provide support for the proposition that the claim must explicitly request a contracting officer’s decision, but that all that need be shown is an “expression of interest,” which may be made implicitly.
The Claims Court relied in its ruling in this case on
Mingus
and on its own previous opinion in
Sun Eagle Corp. v. United States,
In fact, there are two immediate distinctions between the
Sun Eagle
case and this case:
first,
in this case, it is impossible as a matter of logic and in light of the circumstances, to state that there is no implication
*1578
that plaintiff desired a final decision; that is obviously what Stroup desired — a final decision by the contracting officer on its equitable adjustment claim;
second,
the statement as to inconsistency between a request for a final decision and the request for future meetings was clearly ruled on previously by this court in
Contract Cleaning Maintenance, Inc. v. United States,
I.
The September 1 letter submitted to the contractor did not use the explicit words “we request a final decision from the contracting officer,” but it is clear from the language of the letter itself that that is what BBC wanted. BBC considered this letter a CDA claim filed with the authorized representative of the contracting officer. Clearly, BBC desired a response to this letter, and since BBC intended this letter to serve as a statutory claim, it also intended that the contracting officer either grant or deny the claim in a final decision.
Further, the contracting officer was on notice that Stroup wanted a final decision on its claim dating back to Stroup’s November 25, 1988 letter to the Chief of the Claims Section of the U.S. Army Corps of Engineers which requested a prompt decision on the pending equitable adjustment claim. Stroup’s February 21, 1989 telephone conversation with the Government and the former general contractor also notified the Government that it sought a final decision on its claim. This court will not require contractors to do more than to comply as fully and reasonably as possible with the statutory requirements of the CDA when this court has definitively stated that certain “magic words” need not be used and that the intent of the “claim” governs.
See Contract Cleaning,
The September 1 letter was in writing, was submitted to the contracting officer for a decision, requested payment of a sum certain, and gave the contracting officer adequate notice of the basis and the amount of the claim. This court is loathe to believe that in this case a reasonable contractor would submit to the contracting officer a letter containing a payment request after a dispute had arisen solely for the contracting officer’s information and without at the very least an implied request that the contracting officer make a decision as to entitlement. Any other finding offends logic.
II.
As a general proposition, this court clearly stated in
Contract Cleaning,
“[w]e know of no requirement in the Disputes Act that a ‘claim’ must be submitted in any particular form or use any particular wording. All that is required is that the contractor submit in writing to the contracting officer adequate notice of the basis and amount of the claim.”
Id.
at 592. This view is obviously consonant with the CDA itself which, besides the direction given in section 605(a) as set out herein, does not address the specific requirements which a claim must contain. In
Contract Cleaning,
one of the appealed issues was whether certain letters submitted by the contractor requesting payment for contract amounts constituted CDA claims. The letters requested the payment of monies allegedly owed under the contract and indicated the contractor’s willingness to work with the contracting officer to “finalize and conclude this matter,” suggesting that the parties sit down, discuss, and resolve the matter through negotiation.
Id.
at 588-89. The Government in that case disputed whether any of the letters constituted CDA claims, but this court stated that “[t]he letters the appellant wrote to the government ... constituted a claim under the Disputes Act — as GSA itself explicitly recognized with respect to at least one of those letters.”
2
The
Contract Cleaning
*1579
court, contradicting the Claims Court’s statements in its ruling in this case, stated, “[t]he fact that in those letters the appellant frequently expressed the hope that the dispute could be settled and suggested meeting to accomplish that result does not mean that those letters did not constitute claims.”
Transamerica states in its Reply Brief, “[i]t is the position of Transamerica that the [CDA] statutory requirements as interpreted by this Court suggest a common sense analysis to determine whether (1) the contractor asserted in writing and with sufficient specificity a right to additional compensation, (2) the government disputed that right, and (3) the contractor communicated his desire for a contracting officer decision.” This court agrees. Applying such a logical, common sense analysis in this case, BBC’s submissions were sufficient to qualify as CDA claims.
Certification
Despite the fact that the Claims Court stated that once making a finding on the “claim” issue, it did not “deem it necessary to continue to argue the point of proper or improper certification,” the court, in its ruling, reached as an alternative basis for its “claim” decision the issue of the sufficiency of BBC’s certification. The court found that the certification was defective because it was unduly qualified, relying for this finding on language found in the cover letter appended to the certification.
Section 605(c)(1) of Title 41 states on the issue of claim certification:
For claims of more than $50,000, the contractor shall certify that the claim is made in good faith, that the supporting data are accurate and complete to the best of his knowledge and belief, and that the amount requested accurately reflects the contract adjustment for which the contractor believes the government is liable.
The Court of Claims discussed the importance and purpose of the certification requirement in
Paul E. Lehman, Inc. v. United States,
An important objective of Congress was to “discourag[e] the submission of unwarranted contractor claims.” S.Rep. No. 1118, 95th Cong., 2d Sess. 5, reprinted in [1978] U.S.C.C.A.N. 5235, 5239. One method of accomplishing this purpose was provided in section 5 of the Act, 41 U.S.C. § 604, which makes a contractor liable for the amount of any portion of its claim that it is unable to support because of misrepresentation or fraud. Another was the certification requirement.
This court in
Fidelity Construction Co. v. United States,
*1580 In this case there appears to be some inconsistency between what the Claims Court stated at the preliminary hearing and what it said in its ruling on the certification issue. The court stated at its July 12 hearing:
[Yjou’ve got an adequate certification as such, the real issue is whether the cover letter diminishes it to the extent that the general contractor could not be held liable. ...
The certification itself sounds like it does meet the requirements of 605c.... This certification is not qualified. It is accompanied by a cover letter that attempts to inch out of it. However, the individual has put his John Henry to the certification and I think could be held liable.
* * * * * *
The only purpose here that is served is to answer the question of has the contractor put himself in a position where he could be prosecuted for making a fraudulent claim or statement to the contracting officer? ... this kind of self-serving other language that the contractor included in his cover letter, sounded like an attempt to diminish the certification but nonetheless, the certification was made.
(Emphasis added.)
The clear import of the court’s statements at the July 12 preliminary hearing was that in its opinion the certification was valid and that the major policy of certification of being able to hold a contractor personally liable for fraudulent claims was clearly satisfied in this case. The court clearly erred when it ultimately found that the ■ BBC certification was impermissibly qualified by the cover letter’s language.
In
United States v. Turner Construction Co.,
This court has previously found that even when a proposed claim certification lacks certain elements specified in the statutory standard of 41 U.S.C. § 605(c)(1), the certification can still be valid if in “substantial compliance” with the statute and its purposes. In
United States v. General Electric Corp.,
The Claims Court erred in relying upon the “qualified certification” issue as an alternative basis for its judgment. The certification made by BBC was binding, as the court correctly recognized at the July 12 hearing. Further, the allegedly qualifying *1581 statement in the cover letter underscored BBC’s belief that Stroup had “good ground” for its claim. Overall, the certification was, at the very least, in substantial compliance with the CDA’s certification requirement. Thus, the Claims Court’s reliance on the impermissible qualification of the certification as an alternative basis for its decision was clear error.
CONCLUSION
We reverse the Claims Court’s judgment that it did not have jurisdiction over Stroup’s equitable adjustment claim. The claim, considered in context, contained a readily ascertainable request for a contracting officer’s final decision. We further hold that BBC’s certification was valid and not so qualified as to make it ineffective. The certification clearly complied with the chief policy underlying the CDA certification requirement, that being the purpose of submitting the contractor to liability for fraud. We remand to the Claims Court for adjudication on. the merits of the claim for equitable adjustment with interest.
COSTS
No costs.
REVERSED AND REMANDED.
Notes
. The Modification stated, "[i]t is understood and agreed that on account of the foregoing modification of said contract, additional time will not be allowed. It is further understood *1576 and agreed that the adjustment constitutes compensation for all costs and markup directly and indirectly attributable to the change ordered, for all delays related thereto, and for performance of the change within the time frame stated.”
. Transamerica states in this case that the contractor's intent in its submissions "was not only discernable, but clearly understood by the con-trading officer as evidenced by subsequent correspondence." Just as occurred in Contract Cleaning Maintenance, Inc. v. United States, 811 *1579 F.2d 586 (Fed.Cir.1987), the Government in this case referred to BBC's September 1 submission as a "claim.” See March 15, 1989 Contracting Officer letter, and March 28, 1989 Contracting Officer letter. The fact that the Government referred to the operative submission(s) as "claims” was found persuasive by this court in its Contract Cleaning analysis. Id. at 592.