sylvia

Does anyone know of a commercially available database solution available for managing FAR/DFARS data rights assertions?

Our contract is not for a commercial item, but the item we are purchasing in support of our FAR 15 contract is a commercial item for a separate item, stand alone, and distinct from the previous $200,000 we spent with the supplier.

Hypo: I have a new purchase requisition for a commercial item (example: a non-information technology item) in support of a FAR 15 covered contract. Let’s assume that the item is valued under $3,000. After conducting a competitive RFQ with pre-established evaluation criteria based solely on price, I selected the lowest price offeror (a large business and existing approved supplier with my company). I have already spent $200,000 with the same supplier under the same FAR 15 program contract. My question is whether I am able to use a streamlined micro-threshold purchase process and a relatively short list of FAR and DFARS clauses associated with a commercial item, or do I need to apply the longer list of FAR and DFARS and do a more robust purchase order compliance package substantiation because of the aggregate contract spend that has occurred with this supplier under the same prime contract? I am trying to assess whether I need to flow-down a longer list of customized flow-down requirements (including Buy American Act, DPAS, debarment, etc.,) from the prime contract because this micro-purchase tips the scale and becomes in reality a large purchase over the simplified acquisition threshold. Thank you.

Thank you everyone for your helpful input! I think I have enough information to move forward with implementing our process change.

First, I appreciate everyone's helpful comments! Our originals are electronic. We have been printing out the purchase req, purchase order, our justification document, and putting them in a folder. The purchase req is stored in Oracle. The purchase order is stored in Oracle. The justification for award and compliance sign-off document and any other related back-up documentation is stored in SharePoint. Currently, all of those types of documents are printed out and manually routed for internal approval sign-off, and then that approval package is put into a paper file and sent away to sit in a file cabinet. We've been using this process for all purchases regardless of value. My goal was to change the process for micropurchases under $3,500. The idea was to reduce overall waste for these low dollar purchases.I was planning to keep making traditional hard copy paper file folders for everything above $3,500 for now. I'd like to stop making the files as long as the documentation exists in either our Oracle or SharePoint system. We would conduct mini-internal audits to verify that the buyers are completing their justification for price reasonableness. Does this give you enough information to understand what I'm trying to do? Thanks! Sylvia

We are re-evaluating our purchasing processes in an effort to improve our efficiency. One of the pain points we would like to eliminate is creating hard copy paper files for every microthreshold purchase. The DCMA CPSR Guidebook dated October 13, 2015, states that the CPSR analysts are to verify that the contractor's files includes a purchase requisition, purchase order, and documentation that the price is fair and reasonable and the basis for determination. We currently make hard copy paper files for each purchase, and verify compliance on every purchase--even microthreshold purchases. As you can imagine, this process is time-consuming with very little value or benefit except to aggregate the paper for a purchase. Our hard copy paper files contain the purchase requisition, purchase order, and a documentation on why the price is fair and reasonable and the basis for that determination. I would like to abandon making hard copy paper files for the microthreshold purchases, and rely on the identical scanned documentation stored in our Oracle system and SharePoint for the microthreshold purchases. We would create hard copy paper files for the microthreshold purchase samples that are requested by an auditor in support of the CPSR audit. Thoughts? Is there anything that obligates us to keep hard copy paper files for the micropurchases? Sylvia