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About ThomCons

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  1. Yes and Yes. We had several findings and recommendations. We busted our butts implementing all of the corrections prior to the Initial Report being issued. Accordingly, when we responded to our Initial Report, our actions were deemed adequate and was granted an approved system. We did not want to rock the boat at the time of our formal response, as we weighed the risks, and decided to further address this issue after receiving an approved system. This decision was based, in part, of our company also being assigned a new DCMA ACO whom had never dealt with a CPSR. Now that we have the appr
  2. Okay, somewhere this conversation took a left turn. I want to confirm to Vern that it was not a misunderstanding on my part. This was a frank discussion between the Lead Analyst, the Analyst, my Quality Manager and myself. The DCMA Analyst were very clear that if our prime is awarded under FAR Part 15, ALL mandatory flow down clauses are required for ANY subcontract/purchase order regardless if it is commercial or non-commercial, even if FAR 52.244-6 is in the prime contract. DCMA further stated that 52.244-6 could not be IBR, but must be flowed down in full text, which is also questionabl
  3. My firm does DOD and NASA work. DCMA communicated it as a finding and deficiency. We submitted the above stated language to our Lead Auditor via email, but have not received a response. We did not formally submit it in our response, as we did not want to jeopardize receiving an approved system. Now that we have the approved system, we are looking to receive relief from this requirement.
  4. My company recently passed our first CPSR. However, during the audit, DCMA informed us that if our prime contract is issued under FAR Part 15, all required flowdown clauses are applicable to the procurement of commercial items under the contract, regardless of FAR 521.244-6 being included. This requirement has resulted in many difficulties with commercial vendors accepting all of the required government flow downs contained in our prime contracts. Their reluctance to accept these terms and conditions are causing major delays in receiving parts, thereby impacting critical program and project
  5. I would like to poll the subcontractors for their dollar threshold in which written documentation of commerciality is required to be included in the subcontract/purchase order files. Although the government is only required to document this determination for acquisitions of $1M or more, it has been stated in CPSR's that DCMA will not treat subcontract files or purchase orders as commercial during an audit if the files do not contain written documentation and supporting evidence of commerciality. Please share your experiences and threshold levels for this requirement.
  6. Here 2 Help, Based on your knowledge and research provided, would you agree that there is not a subcontractual requirement to issue CAS Notification Letters for 2nd tier and under subcontractors? If the CAS Notifications were not issued, since FAR is unclear on where to issue them, could a CPSR team legitimately state this as a finding in an audit? Please advise, ThomCons
  7. We are specifically trying to clearly determine that if a 1st tier subcontractor issues a CAS covered award to a 2nd tier subcontractor, should the first tier subcontractor issue the CAS notification letter to the prime contractor's CFAO or the 1st tiers CFAO, or the 2nd tiers CFAO. Excerpt from 52.230-6: (l) For all subcontracts subject to the clauses at FAR 52.230-2, 52.230-3, 52.230-4, or 52.230-5? (1) So state in the body of the subcontract, in the letter of award, or in both (do not use self-deleting clauses); (2) Include the substance of this clause in all negotiated subcontracts; and
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