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FAR 44.3 States ?The objective of a contractor purchasing system review (CPSR) is to evaluate the efficiency and effectiveness with which the contractor spends Government funds and complies with Government policy when subcontracting.?

To be granted an approved purchasing system the standard appears to be more stringent than simply complying with a contractor?s contractual obligations ? ??complies with Government policy??.

Is there any guidance on how this is typically interpreted?

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For the sake of discussion, although time does not allow me to research the guidance in the kind of detail that many on this forum do, let me share some thoughts.

Contractor purchasing systems can range along a broad spectrum from commercial best practices tempered by FAR principles, to virtually incorporating the FAR and borrowing its forms and formats. Being something of a renegade, I lean toward commercial best practices tempered by FAR principles, with an adequate but minimal paper trail that is enough to satisfy an outside reviewer that what was done makes business sense and does not fly in the face of what people with some federal training would think is the right way to conduct business. I strongly resist the tendency to use company procedures comprising a purchasing system to narrowly define, by form or template, every single minuscule required step of every required process, or every process for handling every business situation that might arise, although I do recognize that such things tend to increase the comfort level of reviewers and auditors. Taken to the extreme, a contractor would simply write up a purchasing system that looks exactly like the FAR.

My orientation is more of the grunt in the trenches who wonders why we have required ourselves, through our company procedures, to do all this work that seems to add more cost than value, and wonders why the Government hired our company to do things more efficiently if we set up our procedures to be just as inefficient as the Government's.

Co-workers remind me that this is Government work, and the Government will trip over a $20 to pick up a penny.

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  • 2 months later...
FAR 44.3 States ?The objective of a contractor purchasing system review (CPSR) is to evaluate the efficiency and effectiveness with which the contractor spends Government funds and complies with Government policy when subcontracting.?

To be granted an approved purchasing system the standard appears to be more stringent than simply complying with a contractor?s contractual obligations ? ??complies with Government policy??.

Is there any guidance on how this is typically interpreted?

I have been through 3 CPSR's. Typically the government team is going to review and determine if your procurement policies line up with government requirements and FAR. They will examine, in some detail, if you are following your procedures that reinforce policy. I am not sure why your line of thinking is "with a contractor's contractual obligations" because that could entail much more than subcontracting and procurement. By the way, I agree with Cajun's remarks.

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