Pre vs. Post-Award Review - in general, internal review has two main functions:

1. Assurance that files are complete and compliantly maintained; and
2. Identification of areas of improvement that can be addressed via training, template development, process revision etc.

Post-Award Reviews accomplish (2) but aren't much help with (1). Pre-Award Reviews cover both bases, but can be cumbersome and something of a bottleneck when orders are being pushed out the door. 

Once you identify the need for improvement within your system and developed your "go-forward" implementation plan, the hard part begins - you have to sell it to the rest of the company. That's right – your process improvement will sink like a lead balloon if you don't CONVINCE system stakeholders it's a good enough idea to force a change of corporate course. I argue that this is a legitimate, and corporately responsible, course of action for a company to follow. 

Process Improvements - A Definition

I'm going to do some posts on process improvements over the next week or so (mixed in with some additional posts here and there!) so I'd start with a definition of the term itself. This is MY definition, and one I'd like considered and commented upon (of course). This isn't from a book or source, although I may be echoing the thoughts of others much more learned than I. That would actually be great! 

This is a new DFARS clause, but recent events mixed with applied logic provide some useful guidelines for potential application of the "withhold" clause of DFARS 252.242.7005(d) which permits Department of Defense Contracting Officers to withhold up to 5% of payments due to a contractor with one business system operating with significant deficiencies (10% for two or more systems with significant deficiencies). 

As I get ready to begin my day I'll throw some thoughts out there to get things rolling on this topic :)  

Here are two (2) general times a Change Order or Modification is part of the data call universe during a CPSR: 

There are times when DCMA requires contractor documentation of processes that are completed by the government on a regular basis but are relatively impossible tasks for companies going through a CPSR. Two times in particular are:

• The completion of a cost analysis when TINA applies to the procurement; and
• Determination of consultant or SB contractor accounting system adequacy for award of a T&M or LH subcontract.

I'd like to suggest a formulaic approach (process) to this issue:

In the old days, DCMA stayed away from classified contracts - they checked the out-of-SCIF files for compliance documentation but didn't beat you up too much if the evaluative documentation was cloudy and seemingly incomplete. But those are the old day.  These days, your CPSR Data Call will ask you for the dollar value and percentage of classified prime and subcontracts as well as your purchasing system percentage output under those contracts. If it's substantial, you may get a follow-up requesting the clearance level of each prime contract.

In the first post of this series I mentioned that only formal audit results must be provided to DCMA during the CPSR data call period. The definition of "formal audit" is actually up for some interpretation. For example, a fairly rigid definition of "formal audit" could still exclude routine internal review tools like peer reviews from disclosure.

1. Calling a target rate analysis "competitive". Any price analysis that can be performed without two bidders is a noncompetitive analysis. Use target rates as your pre-negotiation objective - subject ID/IQ teams to price competition and greatly increase your competitive metrics.