As defined by FAR Part 44, a CPSR means the complete evaluation of a contractor’s purchasing of material and services, subcontracting, and subcontract management, from development of the requirement through completion of subcontract performance. In the past, Government Contractors could contact DCMA and request this type of review. However, now it is mostly handled based on a request of an Administrative Contracting Officer (ACO), and at times as requested by the head of a Government Agency.
This type of review can be daunting, but it doesn’t have to be. Follow the requirements of FAR Part 44, Create a Purchasing Manual, this includes the documentation you will provide based on the subcontract or purchase order issued, generate various checklists and learn how to do a price and/or cost analysis. All of these actions will become a part of your daily life when issuing a funding document to a Subcontractor, Supplier, or Vendor. Don’t make it harder than it needs to be, but remember that you need to be meticulous with your files; you should document the file to show how you decided to issue that subcontract and/or purchase order to the Subcontractor, Supplier, or Vendor.
Once you have everything set up and all procurement actions documented, bring in an auditor to review your files. This 3rd party will give a fresh set of eyes to these documents and show what might be missing or needs to be tweaked. After you have your internal system in place, you will need to follow these procedures every time. Sometimes the supporting documentation will be less than others, but each procurement file should have all supporting documents to justify the procurement.
If you pass your CSPR the first time around (and if you follow the above actions, you should), then you will be good to go for probably the next three years. If you don’t pass the first time, don’t worry; fix the items that the ACO says are not in accordance with the FAR. Don’t fix anything else, only the things that need correction. Once you have passed and have an approved Purchasing System, don’t let up on your documentation, be ever vigilant, the ACO can request an audit review at any time. As your business grows and you are issuing more and more funding documents to your Subcontractors, Suppliers, or Vendors, the ACO will be aware.
Revolutionary Solutions can help you with your contractor’s purchasing needs. Please feel free to contact us for more information.
Kelly Davidson, Revolutionary Solutions, LLC.