Is your purchasing system ready for a DCMA Contractor Purchasing System Review? Time to dust off those policies and procedures, and make sure your employees are trained on FAR and DFARS requirements.
DCMA has been hard at work reviewing contractor purchasing systems, making several updates in 2016 to the CPSR Guidebook, the most recent being January 18, 2016. In addition, in October 2016, the Director of DCMA issued a Class Deviation from FAR 44.302(a), increasing the CPSR threshold from $25 million to $50 million. Questions remain on how this will impact contractors whose contracts include FAR 44.3 and who are on DCMA’s review schedule. The threshold can be lowered if the ACO determines a contractor’s risk level warrants a review. We have already seen the lower threshold enforced in the early part of 2017 for a couple of our clients.