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  1. In a recently released full & open RFP the Government requires each offeror to provide evidence of an approved purchasing system unless they can prove they do not meet the threshold for a purchasing system review in FAR Subpart 44.3 ($25M). We sell more than $25M annually to the Government so appear to be above the FAR 44.3 threshold, but the Government has never initiated a purchasing system review of our company. We inquired about this with our DCMA ACO a couple of years ago and he indicated we were unlikely to be reviewed and even if he wanted to schedule one it would take at least a year before anyone would be available to audit us. We are primarily a labor services contractor and beyond hiring employees to work under contracts we don't do significant amounts of subcontracting or supply/material purchasing, so I suspect we're considered low-risk from a purchasing perspective (but that's just my guess). The RFP does contain DFAR 252.244-7001 CONTRACTOR PURCHASING SYSTEM ADMINISTRATION-BASIC as well as FAR 52.244-2 SUBCONTRACTS. I understand that DFAR 252.244-7001 defines the requirements for an acceptable purchasing system and outlines the steps that must be taken if the government identifies deficiencies in the system. I also understand that the enabling clause (244.305-71) indicates the Contractor Purchasing System Administration clause should be used in the RFP if the RFP also contains 52.244-2. What's confusing me is that FAR 52.244-2 clearly contemplates a subcontracting process for companies based on whether they do or do not have approved purchasing systems. I can't see anything in the either of these clauses that says something to the effect that only companies with an approved purchasing system can participate in the contract, but that seems to be what the RFP is saying by requiring we must prove our purchasing system is approved. I'm trying to figure out whether I misunderstand the way these clauses work or whether the Government is going a step beyond and requiring an approved purchasing system even though it doesn't have to? This is an RFP primarily for full-time labor services of on-site personnel, so it won't have much supply or material purchasing. I will monitor any responses and reply back with any additional information needed. Thanks for any insight you can provide.
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