DCMA reviewers and consultants alike used a years’ old guidance instruction for performing CPSRs (Contractor Purchasing System Reviews) in ascertaining if a contractor’s purchasing practices represent methods for achieving “best value” in purchasing of services and supplies. This guidance, DCMA Instruction “Consent to Subcontract/Contractor Purchasing System Review (CPSR)” includes an Appendix B that was specifically used in the reconciliation of a contractor’s purchasing or procurement related policies and procedures. That appendix in essence is a checklist with 55 far ranging questions from purely subcontract management issues to Affirmative Action and Standards of Conduct items, and effectively represents criteria and parameters for acceptable government contractor procurement practices in addition to preferred documented company policies and procedures.
But to parrot an old cliché, there’s a new Sheriff in town. The DFARS Business System Rule finalized in February 2012, specifically DFARS 252.244-7001 “Contractor Purchasing System Administration”, sets forth 24 criteria to be used in the determination of an adequate contractor purchasing system. At the time of the Business System Rule finalization there had not yet been a reconciliation of the DCMA “Appendix B” procurement expectations with the criteria set forth in 252.244-7001. However, DCMA issued its DCMA-INST 109 on November 28, 2012 which mirrors the purchasing systems attributes found in the DFARS contract clause. In fact in the “Purpose” section, of the November 2012 instruction, the new instruction supersedes the previous purchasing instruction, and the DCMA-INST 109 is now a stand-alone purchasing system evaluation document. This writer is of the opinion that all of the former CPSR instruction appendices, including the 55 question checklist in Appendix B, are also cancelled. The “Purpose" section of the new instruction goes on to say that the new instruction “…provides procedures for performing contractor purchasing system reviews” which are effectively the DFARS purchasing system provisions.
DCMA has not yet issued any new checklists or questions that reviewers should use during CPSR evaluations. However, the new 24 criteria are in themselves a checklist and replace the basic criteria set forth in the prior DCMA CPSR’s Appendix B document. Furthermore, the 24 criteria are a much more defined indication of what documentation is required in purchasing files. Therefore, we at Redstone have developed our own procurement policies, procedures, and practices checklists that we now use during CPSRs that comply with the most current government requirements.
