JF15992

FAR 44.303 states "A CPSR requires an evaluation of the contractor's purchasing system Unless segregation of subcontracts is impracticable, this evaluation shall not include subcontracts awarded by...

the contractor exclusively in support of Government contracts that are competitively awarded firm-fixed-price, competitively awarded fixed-price with economic price adjustment, or awarded for commercial items pursuant to part 12. My question is does the "in support of Government contracts " include where our firm is a subcontractor to a Government prime contractor? If yes, then does the "competitively awarded fixed-price with economic price adjustment, or awarded for commercial items pursuant to part 12" apply to how OUR subcontract was awarded to us or how the PRIME CONTRACT was awarded?

FAR 44.303 states "A CPSR requires an evaluation of the contractor's purchasing system Unless segregation of subcontracts is impracticable, this evaluation shall not include subcontracts awarded by... the contractor exclusively in support of Government contracts that are competitively awarded firm-fixed-price, competitively awarded fixed-price with economic price adjustment, or awarded for commercial items pursuant to part 12. My question is does the "in support of Government contracts " include where our firm is a subcontractor to a Government prime contractor? If yes, then does the "competitively awarded fixed-price with economic price adjustment, or awarded for commercial items pursuant to part 12" apply to how OUR subcontract was awarded to us or how the PRIME CONTRACT was awarded?

Thanks.

Our policies and procedures now say $3,000 and above we are require to compete or justify not doing so in writing. We are considering changing this, and that it what caused me to ask the question. We recently received CPSR approval and therefore I am a bit hesitant to make changes to our system.

If any others on the forum work for large business prime contractors, let me know what your current practices are.....

At what dollar value do you require either competition or justification to single/sole source? My company uses the micropurchase threshold based on FAR 13.202-2 that states: "(2) Micro-purchases may be awarded without soliciting competitive quotations if the contracting officer or individual appointed in accordance with 1.603-3 ( b ) considers the price to be reasonable. " To me this implies that purchases over the micro purchase threshold require competition. However, others have cited to me the FAR 52.244-5 "Competition in Subcontracting" only applied over the SAT or under a competitive FFP or T&M contract. Thoughts?