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Where do you track CPSR compliance?

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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!

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The P&P establish the required practices. Periodic file reviews determine whether the procurement team has complied with the required practices. I know of many companies that track lots of metrics, but they are not really focusing on using those metrics as a compliance dashboard. Instead, a procurement/compliance function does file reviews.

Hope this helps.

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Regular audits/reviews of transactions, both pre and post award, should be done. Metrics should be maintained on at least the most important criteria, and cause and corrective action pursued. The metric should indicate what level of acceptable non-compliance there may be, if any. the metrics should be reviewed at least quarterly for trends and whether or not corrective action has been effective. Effectively measuring the latter may require a longer review period cycle since correction may not be immediately discernible. The more encompassing the level of pre award review, the less post award review is needed. Some criteria may be done as pre award and some as post award. Poor results in metrics of post awards should push you towards preaward reviews. Keep it simple but effective and tied to chosen CPSR criteria.  

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