The Federal Funding and Accountability Transparency Act (FFATA) requires prime contractors to report their first-tier subcontracts and grant recipients to report their first-tier subawards using the Federal Funding and Accountability Transparency Act Subaward Reporting System website.
Topics: Employee & Contractor Compensation, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), System Award Management (SAM), Government Regulations, Federal Acquisition Regulation (FAR)
Why do contractors have to do market research? Simply put, you signed a contract with the US Government or a subcontract with a prime contractor that expects it – yes, it is contractually required. Plus, it is one of the most often reported contractor purchasing system review (CPSR) findings.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Commercial Item Determination
The FAR Council issued a proposed rule on January 15, 2025, to expand the CUI requirements into FAR under Executive Order 13556 Controlled Unclassified Information. Controlled Unclassified Information is information that the government creates or possesses, or that an entity creates or possesses for or on behalf of the government, that a law, regulation, or governmentwide policy requires or permits an agency to handle using safeguarding or dissemination controls. CUI may not be released to the public.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Cybersecurity
We have had several clients tell us they have purchase orders under the Truthful Cost or Pricing Data (TINA) threshold for what they believe to be commercial purchases. They run a quick search on the purchase order (PO) and find there are no Federal Acquisition (FAR) or Defense FAR Supplement (DFARS) clauses in the agreement even though the prime contract is to the U.S. Government.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Federal Acquisition Regulation (FAR)
The FAR Council issued a proposed rule on November 29, 2024 to amend the FAR to increase acquisition related thresholds for inflation.
Topics: Proposal Cost Volume Development & Pricing, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Estimating System Compliance
The Government wants to pay a fair and reasonable price for products and services that they purchase and expects you to pay your suppliers a fair and reasonable price. FAR 52.244-5 Competition in Subcontracting includes the requirement to select subcontractors and suppliers on a competitive basis to the maximum extent possible. What happens when you receive only one bid or there is only one source that can perform the effort? Well, the purchase becomes sole source – and yes, the requirements have just increased significantly. If the purchase exceeds the micro-purchase threshold, yes $10,000, you must document the justification as sole source. While it sounds pretty simple, for example, when the customer directs a part to be purchased from a specific supplier, you just check the box “customer directed” and move on. Oh, if that were only the case. Even when a purchase is customer directed, more documentation is necessary. It is never as easy as checking a box. When you are directed to buy from a supplier, you must still document the price is fair and reasonable. If the price is not fair and reasonable, it is your job to inform the government.
Topics: DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)
Both the Federal Acquisition Regulations (FAR) used by Federal Agencies to acquire products and services to support their operations and 2 Code of Federal Regulations (CFR) 200 used by Federal Agencies for grants to support Federal programs set forth requirements that the organizations awarded contracts or grants have an established purchasing/procurement systems. Before getting a procurement under a grant, you must determine if any lower-tier organization is either a subrecipient or a contractor (read more in this article, “Understanding your Lower-Tier Relationships with Subrecipient and Contractor Determinations under 2 CFR 200.” In this article, we are only dealing with contractors under 2 CFR 200 and subcontractors under the FAR.
Topics: Compliant Accounting Infrastructure, Contracts & Subcontracts Administration, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Grants & Cooperative Agreements (2 CFR 200)
Looking to streamline your procurement process? Now is the perfect time to begin reviewing your complete source to pay process to increase efficiency, productivity, integration, and revenue.
Topics: Compliant Accounting Infrastructure, Contractor Purchasing System Review (CPSR), Deltek Costpoint, Manufacturing Operations Consulting
Probably now. Depending on the type and dollar amount of your subcontracts, FAR 52.244-2 Subcontracts clause requires a contractor that does not have an approved purchasing system (never been reviewed or is disapproved) to obtain written consent from the Contracting Officer before subcontract award.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)
There is no such thing as a risk-free interaction with the Government when it comes to submitting data.
Topics: Proposal Cost Volume Development & Pricing, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Estimating System Compliance