RGCI-Updated DCMA CPSR Handbook

DCMA updated the Contractor Purchasing System Review (CPSR) Handbook on September 10, 2021.

What are the Changes?

There were no substantive changes except for the addition of the Level II CAR process in Part 4 and a threshold update to the small business subcontracting plan in Section 5.5 which is discussed below. Parts 1 through 3 were updated to include:

  • Summary descriptions of the different CPSR reviews.
  • CPSR teams process for coordinating with the contractor and the forms to be completed (e.g., pre-review questionnaire, risk assessment, universe of contracts).
  • The universal description as all purchasing transactions within a 12-month period.
  • Whether the review will be virtual or onsite, and a description of the process (e.g., entrance conference, submission of requests for data, daily briefings and a final briefing).
  • Procedures when a Level II CAR is issued, corrective action plans, approval or disapproval of system and the timeline for contractor and government responses.

Any Other Changes

Part 5 has been restructured with Sections 5.1 through 5.30 addressing the 30 purchasing criteria using a structured format and bullets --title, introduction, FAR/DFAR and other references, applicability Pre-Review, Review, and Post review unless there are other requirements (e.g., thresholds, exemptions, best practices, etc.).

Section 5.5 Small Business Subcontracting Plan Changes

Section 5.5 Small Business Subcontracting Plans has been updated to include the increased threshold of $750,000 for prime contracts awarded after June 30, 2020 to submit a small business subcontracting plan, added regulatory references, and a Post-Review Section as to whether the policies and procedures allow the contractor to be in compliance with small business goals and whether the policy is acceptable.

Overall, a lot of unnecessary details were removed in the updated manual.

Redstone GCI is available to assist contractors in assessing their current purchasing system policies and practices to ensure they meet the DFARS requirements. Redstone GCI assists contractors throughout the U.S. and internationally with understanding the Government’s expectations in applying FAR requirements.

Learn More About Our Contractor Purchasing System Review (CPSR) Services

Written by Lynne Nalley, CPA

Lynne Nalley, CPA Lynne is a Director with Redstone Government Consulting, Inc. providing government contract consulting services to our clients primarily related to Commercial Item Determinations and support, Cost Accounting Standards, DFARS Business System Audits, Proposals, and Incurred Cost. Prior to joining Redstone Government Consulting, Lynne served in several capacities with DCAA and DCMA for over 35 years. Professional Experience Lynne began her career working with DCAA in the Honeywell Resident Office, Clearwater, FL in 1984. Lynne’s experience included various positions which involved conducting or reviewing forward proposals or rate audits, financial capability audits, progress payments, accounting and estimating systems, cost accounting standards, claims and disclosure statement reviews. She is an expert in FAR, DFARS, CAS and testified as an expert witness. Lynne assisted in drafting the commercial item guidance for DCAA Headquarters. Lynne was assigned as a Regional Technical Specialist where she provided guidance to 20 field offices on highly complex or technical issues relative to forward pricing, financial capability or progress payment issues. As an Assistant for Quality, she was involved in reviewing and ensuring audit reports were in compliance with policy and GAGAS as well as made NASBA certified presentations to the staff including but not limited to billing reviews, CAS, unallowable cost and progress payments. To enhance her experience in government contracting, Lynne accepted a position with DCMA in 2015 as part of the newly organized DCMA Cadre of Experts in the Commercial Item Group. This included performing reviews of prime contractor’s assertions and/or commercial item determinations as well as performing price analyses. Lynne was a project lead and later became a lead analyst where she engaged with the buying commands on requests and reviewed price analysis reviews performed by a team of 5 analysts. She also assisted the DCMA CPSR team relative to commercial items and co-instructed the Commercial Item Training presented to DCMA. Education Lynne earned a Bachelor of Science Degree in Accounting from the University of Central Florida. Certifications State of Florida Certified Public Accountant State of Alabama Certified Public Accountant Defense Acquisition Workforce Improvement Act (DAWIA) Level III- Auditing DAWIA Level III – Contracting

About Redstone GCI

Redstone GCI is a consulting firm focused on fulfilling the needs of government contractors in all areas of compliance. With a singular mission to help contractors through the multiple layers of “red tape,” we allow contractors to focus on what they do best – support their mission with the U.S. Government. We are home to a group of consultants made up of GovCon industry professionals, CPAs, attorneys, and retired government audit and acquisition professionals.

Our focus and knowledge of audit and compliance functions administered by DCAA and DCMA will always be at the heart of what we do. However, for the past decade, we’ve strategically grown to support other areas of the government contractor back-office with that same level of focus and expertise. We’ve added expertise in contracts management, subcontract administration, proposal pricing, various software systems, HR and employment law, property administration, manufacturing, data analytics/reporting, Grant specialists, M&A, and many other areas. When we see a trend in the needs of contractors, we act to ensure we can provide the best expertise in the market to fulfill those needs.

One thing our clients can be certain of is that with the Redstone GCI Team in your corner, there is no problem too big and no issue too technical for our team to tackle.

Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR)