Redstone Government Consulting Blog | Contractor Purchasing System Review (CPSR) (6)

On September 5th, DCMA issued a letter to the National Defense Industrial Association (NDIA) addressing industry concerns raised at a meeting with DCMA on April 25, 2013.  We will highlight some key points in the letter that will help contractors deal with DCAA’s assertions which often times are not supported by regulations. The letter reinforces that it is DCMA that determines if a contractor’s business system is compliant or not and if a Corrective Action Request (CARs) is necessary.

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.