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Purchasing CPSR Compliant


               For those subject to Contractor Purchasing System Reviews (CPSR), Unanet functionality can
               be used to track the necessary information for compliance.

               Procurement Under US Government (USG) Contracts

               Overview
               The USG has the powers of taxation and spending from the Constitution and buys more goods
               and services than any other person/entity. The Department of Defense is the largest buyer (via
               contract) in the USG. In essence, contractors are spending the taxpayer’s dollar on behalf of the
               USG. There is significant risk for the USG and taxpayer when contractors procure goods and
               services in support of USG contracts, so USG procurement is highly regulated environment as a
               result. Conducting Contractor Purchasing System Reviews (CPSRs) is one of many ways for
               the USG to manage risk.

               CPSR Objective (FAR 44.301)

               The objective of the CPSR is to evaluate the efficiency and effectiveness with which the
               contractor spends USG funds and complies with USG policy when subcontracting. CPSR
               provides the Administrative Contracting Officer (ACO) a basis for granting, withholding, or
               withdrawing approval of the contractor's purchasing system. The CPSR looks at direct billable
               purchases to protect the USG's interests and manage/mitigate risk. The CPSR includes
               reviewing the purchasing process and ensuring sound practices are in place that are compliant
               with the FAR and public laws.

               Defense Contract Management Agency (DCMA) is charged with reviewing contractors'
               purchasing systems when the purchasing system is effectively under the cognizant of a DCMA
               ACO. DCMA CPSR Group's Mission: "Ensure that [Government] suppliers have purchasing
               systems in place that contribute to effective subcontract management. Effective subcontract
               management includes development of, as well as performance to internal policy and
               procedures, public law and adequacy of cost and price analyses performed on subcontractors."
               For DFARS system criteria, see section 252.244-7001(c) here:
               https://www.acq.osd.mil/dpap/dars/dfars/html/current/252244.htm
               Below are the current DCMA CPSR P&P requirements and report elements:


                   1.  Policy and Procedure Manual
                   2.  Truthful Cost or Pricing Data (TINA)
                   3.  Cost Accounting Standards (CAS)
                   4.  Prior Consent and Advance Notification
                   5.  Small Business Subcontracting Plans
                   6.  Protecting the Government's Interest with Subcontracting with Contractors Debarred,
                       Suspended, or Proposed for Debarment
                   7.  Limitation on Use of Appropriate Funds to Influence Certain Federal Contracting and
                       Financial Transactions (PTI/Anti-Lobbying)
                   8.  Defense Priorities and Allocations System (DPAS)
                   9.  Federal Funding Accountability and Transparency Act (FFATA) of 2006
                   10. Counterfeit Parts Mitigation and Surveillance




               APPENDIX B: SUPPLEMENTAL INFORMATION
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