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Good morning! As a government services contractor, we have recently purchased software for a purchasing system. We understand that all subcontracts should be entered into the system, but I am wondering if we need to enter for audit compliance - items such as rent contracts/Purchase Orders or contracts/Purchase Orders we have with outside firms for support services such as recruiting or marketing. These obviously impact our rates. Is it of your opinion that these Purchase Orders be entered into our purchasing system module to be compliant for Government audit? Thank you!
Brief Background: Our DCMA/CACO requested hard-copy of 45 PO files (initially requested 70) in preparation for a surveillance review. We have an approved purchasing system that is 100% electronic/paperless. We've had a paperless SAP system since 2011. Question: Is there a regulation or guidance that supports the DCMA/CACO request? If, No... how would you suggest we respond to our CACO without upsetting him? He has threaten to recommend a full CPSR if we do not provide the hard-copy PO files.
I have a substantial CPFF Contract awarded to my company at one location. We have a location in a different state (different cage code etc.) that will work on the contract as well via an IOT. The out of state location has an approved purchasing system whereas my location does not. The out of state location is planning to issue a subcontract. Keeping in mind, the contract was issued to my location without the approved purchasing system which ACO gets the notification/consent request? Mine or the one at the other company location. Also, is consent required or advanced notification? (if issued from my purchasing department at my location definitely requires consent.) There's NRE in the subcontract, otherwise its FFP and its in access of 5% contract value.
Do you know of any defense contractor(s) that have excluded any interorganizational transfers from the population submitted to DCMA for CPSR review? If so, did they go so far as to exclude interorganizational transfers at price for commercial items? Do you think it is reasonable for a defense contractor to interpret FAR 44.101 and FAR 44.303 to allow for exclusion of any (or all) interorganizational transfers (at price or cost)?