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  1. 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 contract does not create any such automatic exemption. I have been unable to locate, within in the FAR, any acquisition supplements or any other contracting resources, any support for the company's position. Is anyone else observing this exemption, and if so what is the basis for it?
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