A colleague's company has engaged a consultant to help them prepare for an upcoming CPSR. The consultant is telling them that, in a large business, the Contract Administrator (CA) and Subcontracts Administrator (SCA) cannot be the same person and that doing so would result in a deficiency finding during the audit.

It is my opinion that they can be the same person, as long as company policies do not dictate that it must be 2 different people. The company has organized its staff to do the whole job – contracts and subcontracts/selling and buying - because they support only one account. That way, the account knows who to go to for any contracting-type issue. They get to train their folks in more than one area, which is a benefit to them personally on a professional level.

My inclination is that DCMA cannot tell prime contractors how to run their contracts and procurement offices, nor can there be a set of rules for large businesses regarding this subject vs. small business. And we cannot find any FAR or regulatory support for such an opinion.

Your thoughts and guidance would be most appreciated. Thank you.

Any thoughts here? Thank you!

They may be viewing this as a checks and balances - like not having Purchasing and Receiving done by the same person.

I don't see any problem with the prime CA and the SCA being the same person, so long as the company's policies/procedures/instructions are separate. That's an efficiency/cost savings thing, and would be especially applicable in a smaller business where there might not be workload for a FTE in each silo.

Besides, that's the way we did it (a while ago) in a previous major DOD contractor. The boss' philosophy was that every acquisition professional should be able to manage a prime contract or manage a subcontract or procure goods/services. And that's the way he organized the department. Passed every CPSR, too.

Granted, that was then. But I don't see where having one person perform different functions IAW different/separate command media/standards would be an issue.

Hope this helps.

This should be easily answered. FAR 44.305-1 states the ACO shall approve a purchasing system only after determining that the contractor's purchasing policies and practices are efficient and provide adequate protection of the Government's interest. Have your colleague require the consultant to explain how the practice of having the same person fill the roles of CA and SCA is inefficient and does not adequately protect the Government's interest. If the consultant cannot provide an answer that passes the smell test, your colleague may want to factor that into the decision on whether to follow the consultant's advice.

Any thoughts about Program (Project) Managers performing the Contract Manager function in a large company? In other words, the PM interfaces with COTR and CO on Government Contracts. Granted it is an engineering firm but.....

There is no law against it, and it should be fine if the program manager knows enough and can be trusted to use good judgement.