My main question revolves around whether SSJs are required to purchase commercial items that go into commercial and non-commercial products that are made and sold to the government. I’ll caveat by saying these purchases are not directly tied to prime contracts. These are products/components purchases for inventory and then incorporated into a product sold to the government and, in some cases, other companies (we do have commercial price lists for some of these products).
Backstory – I work for a large defense contractor who historically provides services (very little product) to both Federal Civ and DoD clients. Over the last two years, we have acquired multiple product companies, which positions ourselves to sell those companies products (both commercial and non-commercial) as total package solutions (product & services) on a much larger scale. Our company has a certified purchasing system and a procurement policy that mostly aligns with FAR/DFAR as one would expect. The policy addresses indirect & direct purchasing/subcontracting, and the section addressing single/sole source requires SSJs for both indirect & direct purchasing.
Issue - As we have integrated these new companies, rolling them in under our procurement policy has been a struggle as each did not have formal purchasing policies. So, the level of documentation we required (SSJ, formal solicitations, award justification, etc.) has been challenging. As you might imagine, the argument is, “Why is this required if we are buying is for inventory, not direct resell? Why is all this documentation required?”
It would seem to reason that when purchasing commercial products that generally go into inventory before being assembled into a product, that areas of our policy would not apply, i.e., SSJs. The product designs include specific components from specific suppliers (think circuit boards and the like), so to use other suppliers isn’t an option without adjustment to design; some have helped on the designs.
Does it make sense to issue a procurement directive (of sorts) or a blanket SSJ for certain suppliers critical to the product, which would apply to all future purchases of those items from those suppliers?
Opinion question:
Given the change in our company (buying product companies), would it make sense to consider creating a separate commercial purchasing policy to govern purchases that are not directly tied to a prime contract? I don’t know for sure, but I would assume companies like Raytheon, BAH, Northrup Grumman have separate purchasing policies to address the purchase of commercial materials for products that are made and resold.
Anyone aware of any resources that would address these types of purchases for products or maybe a sample commercial purchasing policy (something not tied to FAR/DFAR commercial items definition). A policy a company like Cisco or AT&T might use for buying the products they make?