Redstone Government Consulting Blog | Contractor Purchasing System Review (CPSR)

The launch of the CAPE (Consolidated Administration and Processing of Entries) system by U.S. Customs and Border Protection marks a significant opportunity for importers to recover duties previously paid under IEEPA tariffs that were later ruled invalid by the U.S. Supreme Court. By enabling consolidated refund claims and streamlining the process through the ACE portal, this program reduces administrative burden and accelerates reimbursement. For importers, especially small businesses that directly paid these tariffs, this development is highly relevant because it provides a time-sensitive pathway to reclaim costs, improve cash flow, and correct past overpayments in a changing tariff environment.

Topics: Contracts & Subcontracts Administration, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Manufacturing Operations Consulting

Government contractors should be aware of a proposed FAR rule implementing FY 2023 NDAA Section 5949 that will prohibit the use of certain covered semiconductor products and services in federal procurements by December 23, 2027. The rule introduces new certification, disclosure, and supply chain review requirements that may significantly impact sourcing, compliance, and contract performance.

Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Commercial Determination, Manufacturing Operations Consulting

The FY 2026 NDAA, Section 1807, directs DoD to maintain Project Spectrum, a no-cost online platform offering cybersecurity training, tools, and resources for small and medium-sized government contractors. Originally launched in 2019, the platform supports CMMC compliance and is available to any company pursuing DoD work, regardless of current contract status.

Topics: Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Cybersecurity, Commercial Determination, Manufacturing Operations Consulting

The Department of War has introduced an Acquisition Transformation Strategy aimed at prioritizing commercial solutions and expanding participation from nontraditional contractors. While the direction signals reduced barriers and faster acquisition, contractors must evaluate how evolving expectations, timing, and risk tolerance will affect compliance, pricing, and engagement strategies.

Topics: Accounting System Compliance, Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Commercial Determination

The United States Supreme Court has ruled that the International Emergency Economic Powers Act does not authorize presidential tariffs, effectively invalidating prior IEEPA-based duties. This decision creates uncertainty around potential refunds and shifts attention to new tariff measures now in effect. Importers and trade compliance teams must reassess duty exposure, documentation practices, and forward-looking trade strategies in a rapidly changing regulatory environment.

Topics: Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Estimating System Compliance, Manufacturing Operations Consulting

Have you heard that Unanet recently released a new add-on called AIM? AIM is Unanet’s Asset, Inventory and Manufacturing add-on to their powerful GovCon ERP. AIM has been in the marketplace for many years and was recently incorporated into Unanet’s offerings to support GovCon customers, particularly for audit readiness in the Materials Management & Accounting System (MMAS). This article answers the 5 Ws to help organizations determine whether AIM meets their operational needs.

Topics: Accounting System Compliance, Contractor Purchasing System Review (CPSR), Unanet, Government Property Management, Material Management & Accounting System (MMAS), Manufacturing Operations Consulting

Section 1826 of the FY 2026 National Defense Authorization Act shifts DoD treatment of nontraditional defense contractors from discretionary to mandatory exemptions from key cost and business system requirements. With no dollar threshold and rulemaking still pending, government contractors must evaluate timing, contract status, and downstream compliance implications.

Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Commercial Determination

Department of Defense class deviations are implementing the Revolutionary FAR Overhaul across multiple FAR and DFARS parts, with effective dates beginning as early as February 1, 2026. These changes affect clause structure, regulatory language, and timing considerations, requiring contractors to closely evaluate solicitations, flowdowns, and contract terms to maintain alignment with updated requirements.

Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)

On December 5, 2025, the Department of Justice (DOJ) reported another settlement under the False Claims Act (FCA) related to cybersecurity. Swiss Automation agreed to pay $421,234 to the Government as a result of failing to provide adequate cybersecurity controls for drawings of parts supplied to Department of Defense (DoD) prime contractors. The qui tam suit under the False Claims Act (FCA) was brought forward by a whistleblower, not an Information Technology (IT) employee, but a Quality Control Manager of the company. The whistleblower received $65,291.

Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Cybersecurity, Commercial Determination

On November 26, 2025, the Office of Management and Budget (OMB) issued the 2025 Compliance Supplement. The Supplement outlines the compliance requirements to assist auditors in understanding the Federal program’s objectives, procedures and requirements when performing a Single audit for fiscal years beginning after June 30, 2024. The Compliance Supplement is normally issued in the spring of each year; however, OMB delayed its issuance to incorporate significant updates to 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, in October 2024. In order to assist auditors with the different requirements, Part 3 Compliance Requirements of the Supplement was divided into two Parts for audit testing as follows:

• Part 3.1 for awards subject to 2 CFR 200 prior to October 2024 and
• Part 3.2 for awards after October 1, 2024

Topics: Accounting System Compliance, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Grants & Cooperative Agreements (2 CFR 200)