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About bulgheroni

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  1. Thanks for your comments on the subject. Other than the absence of 52.244-2, the subcontracts I am concerned with clearly meet the criteria for belonging in the CPSR universe, i. e. they are under primes other than competitively awarded FFP or FFP-EPA, and they are not awarded under commercial item primes. Such subcontracts missing the Subcontracts clause (for no apparent reason) are not numerous, but there are some, and our staff is citing that as the only reason for exclusion. If it makes any difference, our company does have a longstanding approved purchasing system. I am still not g
  2. Correct, our company was indeed recently selected for CPSR, and the subcontracts coded as exempt, some of which are in the class I described, were not included in the universe. We do not otherwise treat our subcontract differently; all subcontracts are documented the same way, subject to the requirements of each prime contract. I believe the company is endeavoring to minimize the risk of CPSR criticism by seeking to exclude everything from the universe that is legitimately exempt, but it seems we are overstepping that definition based on the dubious interpretation of the clause. It
  3. My company believes that if a prime contract does not contain the clause 52.244-2 "Subcontracts", then all subcontracts awarded under that prime are exempt from purchasing system review under FAR Part 44. This has been enshrined in our policy, and even contains the guidance to contact the Contracting Officer when the clause is omitted, to ensure that the omission is intentional. The reason given is that FAR 52,244-2(i) says "The Government reserves the right to review the Contractor’s purchasing system as set forth in FAR Subpart 44.3". I contend that the absence of this line in the cont
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