I have recently moved to be the sole procurement analyst at a smaller agency's contracting activity and have a challenge on my hands as we are moving to be more compliant with the push for using CPARS and we are currently using PPIRS. While it's obvious that your garden variety support contractor should never see anything in CPARS or PPIRS that affects anything not related to thier specific firm that they are the designated POC on due to potential OCI, what about contracted 1102s working in a contracting activity? Are they also forbidden from seeing things in CPARS and PPIRS? The DoD Policy Guides don't seem to give any leeway in this regard, but support contractors who are acting in an 1102 capacity would seem to be a different case to me. Is there any other specific policy prohibiting contractors from using or seeing the output from these systems aside from general fears about potential OCI? Our contracted 1102s are from very small businesses to help mitigate that sort of issue and sign extensive NDAs and disclosure documentation to prevent OCI. Is that good enough? Again, what is the governing policy here beyond the DoD Policy Guide for CPARS? Is there any? Or legal precedent?
This problem is acute for my contracting activity because we have, in an activity of only 20 personnel (all of which are operational 1102s but myself, even our SPE/Director signs contracts and our EAs, such as they are, are purchasing agents) less than half our Government and the rest are all contracted out 1102s. I'm the designated focal point for CPARS and PPIRS (I'm also Government) but using these systems in source selections and in contract administration, just in terms of getting the records properly populated and inputed into the system, is going to be difficult or well nigh impossible if a contractor can't touch or see it at all. Right now the three team leads/contracting officers are feds and all the specialists working under them with the exception of two are contractors.
Also, if this prohibition on any support contractor seeing the information is only a DoD policy, does it apply or not apply to civilian agencies if they are using CPARS, which is a DoD system? Or is the policy Government-wide but just documented in a strange place?
Any helpful tips on how to deal with this situation would be appreciated. My overall question would be what the policy for this is. DoD guides and training say contractors aren't to see the information under any circumstances, but I cannot find anything in the FAR or CFR that would have such a strong prohibition.