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 getting an answer to my question, which is, are there indeed other companies in the industry, who are currently awarding subcontracts and are subject to purchasing system reviews, who are using this specific reason to exclude subcontracts from the CPSR universe? And if so, what is the basis for that decision? I would like to hear the reasoning from someone who is actually doing it.