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Thank you, Vern.

Scenario: I obtain a CCCPD for a subcontract valued at >$700K. I then increase the value of the subcontract by $200K. Do I need another CCCPD? Of course this assumes that none of the TINA exceptions apply. Many thanks for your help.

No thoughts/advice/guidance at all?

Good morning. Despite my best search efforts, I've been unable to find definitive guidance on Government acceptability of third party accounting system review certifications. What is the Government's current stance on the subject? Would a formal certification from an accounting firm that specifically addresses the areas on the SF1408, along with a copy of said SF1408, suffice? Or is the Government accepting only DCAA evaluations/opinions? Your thoughts and guidance would be most appreciated. Thank you.

Any thoughts here? Thank you!

A colleague's company has engaged a consultant to help them prepare for an upcoming CPSR. The consultant is telling them that, in a large business, the Contract Administrator (CA) and Subcontracts Administrator (SCA) cannot be the same person and that doing so would result in a deficiency finding during the audit. It is my opinion that they can be the same person, as long as company policies do not dictate that it must be 2 different people. The company has organized its staff to do the whole job – contracts and subcontracts/selling and buying - because they support only one account. That way, the account knows who to go to for any contracting-type issue. They get to train their folks in more than one area, which is a benefit to them personally on a professional level. My inclination is that DCMA cannot tell prime contractors how to run their contracts and procurement offices, nor can there be a set of rules for large businesses regarding this subject vs. small business. And we cannot find any FAR or regulatory support for such an opinion. Your thoughts and guidance would be most appreciated. Thank you.

As we work to develop a supplier Representations and Certifications package for use under Government prime contracts, how does one best determine what FAR/DFARS clauses should be in the package? Is there a reference or suggested methodology? Having used many Reps and Certs packages through the years, but never having been tasked with developing a new package, I'm asking for guidance on how best to start. Of course, we could start with previously-developed packages, but that approach doesn't improve our developmental knowledge. Your thoughts and guidance would be most appreciated. Thank you.

Thank you, sir.

Must a prime contract contain FAR 52.244-6 in order to award a commercial subcontract under that prime contract? Through the years, I've heard both 'yes' and 'no'. And just today, I heard 'yes' and 'no' from 2 different, very experienced Government procurement folks. I'm not sure I've ever received a definitive answer to the question. Nor am I sure there even is a definitive answer. Your thoughts would be most appreciated. Thank you.

Does the Government expect every purchase of commercial items to be supported by a formal, written commercial item determination such as that provided in Versions 1 and 2 (draft) of the DOD Commercial Item Handbook? We're currently drafting a commercial items procurement procedure and I cannot find definitive guidance on the subject. From a prudent business perspective, I see where such determinations would be beneficial. But, in our predominantly commercial environment, having to draft such a determination for every award could become onerous and, possibly, hard to support from a 'return on investment' perspective. I would greatly appreciate your thoughts. Thank you.

Thanks, everyone. This helped to clarify the requirement.

If a contractor has a CPSR-approved purchasing system, is that contractor then never required to obtain consent or provide advance notification (except in accordance with 52.244-2 ( and (d))? We are currently debating the requirements of FAR 52.244-2 (which, in my opinion, contains a far amount of ambiguity), and are faced with several competing interpretations. Your guidance would be greatly appreciated. Thank you.