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Found 12 results

  1. Hello all, I have recently moved from a DoD contractor to an NGO without an Approved Purchasing System. This has not been an impediment for them, as they have only performed as a subcontractor under a handful of USAID prime contracts. However, there is interest in expanding their contracts portfolio and a desire to move beyond subcontracting into prime contracting. As that is the case, I have begun the process of determining how prepared we are as an organization for a CPSR audit. So far, it looks pretty grim. Little to no file documentation, no price/cost analysis being performed, polic
  2. What should we do to ensure performance from a company that just lost approval of their purchasing system as a result of a recent CPSR? Is requesting "Assurance of Performance" sufficient, or should we do something else?
  3. My company recently passed our first CPSR. However, during the audit, DCMA informed us that if our prime contract is issued under FAR Part 15, all required flowdown clauses are applicable to the procurement of commercial items under the contract, regardless of FAR 521.244-6 being included. This requirement has resulted in many difficulties with commercial vendors accepting all of the required government flow downs contained in our prime contracts. Their reluctance to accept these terms and conditions are causing major delays in receiving parts, thereby impacting critical program and project
  4. Hello my Contract and Subcontract friends! It seems a pretty important update/change to the FAR escaped my notice. I'm curious how you all stay updated on the many evolving rules/regulations/best practices/etc. Any advice is appreciated!
  5. 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
  6. My company is interested in setting up CPSR-compliant policies and procedures. In my previous lives, I have tracked compliance actions (ie, EEO, TINA, Reps and Certs, etc) at the subcontract level (covering all subsequent Task Orders) and I've also done it on a per Task Order basis. I think each have their own unique pros and cons. I have my own preference but would like to hear the experience/thoughts of others. Thanks!
  7. For those of you who have had recent annual surveillances by your ACO/CACO (or delegate)... (1) how many PO files have they requested? 2) how formal has the surveillance process been (e.g., is there a report, expectation of a reply, and a final determination)?, and 3) how long has the reviews lasted (e.g., # of days, # of weeks, # of months)? Thank you for your help!
  8. 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.
  9. 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 is
  10. 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)?
  11. An article of mine titled "Contractor Purchasing System Reviews - Not So Different from 1991" was published in the May issue of Contract Management magazine. My contention is that CPSRs are pretty much the same today as they were in 1991 when NCMA published my first article about CPSRs. I would appreciate feedback from anyone reading the article about my positions on source selection, price reasonableness and clause flow down.
  12. Hello, It appears that DCMA has taken down the link which leads to the DCMA guidebook on Contractor Purchasing System Reviews (CPSR). http://guidebook.dcma.mil/26/guidebook_process.htm Does anyone have a soft copy that they can send me or know of a different location to download the guidebook? I am helping my company prepare for an upcoming CPSR and believe that this guidbook would be tremendously useful. I have seen a number of CPSR briefings which claim that Appendix B of the guidebook has 55 key topic areas which DCMA auditors expect to be covered as part of a contractor's policies and p
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