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June 30, 2014

CPSR Analysis of Signature Authority

Signature authority is a particular audit point for CPSR Teams. Here are factors evaluated by the team as they perform your review: 

Policies, Procedure and Documentation: You'll need a policy that clearly states he procurement has the sole authority to commit the company to performance. THIS INCLUDES THE SOLE AUTHORITY TO PROCESS A PROCUREMENT ACTIVITY (more below). You must also maintain and provide (during your data call) a signature matrix that shows thresholds for approval by title/level. 

Note: DCMA sees a signature authority matrix as controlling over both administration and approval. That means if a buyer has a $25K signature authority then they should not be touching files with a value of $26K - those files are literally above their pay grade for any task related to that file without delegation. This is relatively easy to fix - create an Administration Matrix as well. SM says what they can sign, AM says what they can touch and administer prior to approval and signature. 

File Review Points: Approvals should occur at least three times during the procurement process: 

1. By senior Ops prior to requisition submission; 
2. By Procurement prior to processing the procurement activity 
3. By Procurement during the award process (execution is approval to commit). 

In between 2 and 3 there can also be approvals gained during a pre-award review process (signature and commitment not approved until activity reviewed by internal audit function). 

Obstruction of or failure to obtain appropriate approvals can result in the following findings: 

1. Failure to obtain upper Ops approval prior to requisition processing: Minor finding related to inability to follow internal processes. 

2. Processing procurement activity without approved requisition: Potentially significant finding regarding inadequate lead time (no req means lead time clock did not start - team can calculate lead time as 0 days). Also, failure to follow P&P regarding requisitions and finding for inadequate file documentation. Also potential issues with after-the-fact SSJ submission. 

3. Processing procurement activity and selecting awardee prior to requisition submission to Procurement (submission of "complete package" with req): Significant Finding of usurpation of procurement authority. Also findings on inadequate source selection, price analysis, etc. 

4. Work starts prior to procurement approval and award: Significant finding for usurpation of procurement authority (note the Anti-Deficiency Act does not apply to contractors so no public law finding will result). Also findings on inadequate source selection, price analysis, lack of consent to subcontract, etc. 

Findings related to signature authority, while not implicating public laws, can create severe issues during a CPSR. In particular, evidence of short/inadequate lead times mixed with low competitive numbers and evidence that requisitioners are "playing procurement" will lead to a significant finding of Usurpation of Procurement Authority 95 times out of 100. This is maybe the MOST significant finding - it leads to a conclusion that Procurement is not running procurements so all proposed corrective actions are in danger of failure depending on the whims of Operations. That is not the sort of purchasing system DCMA rushes to approve. 

There are ways to fix these issues of course, and I would argue implementing these fixes are more important that any other process issue on your plate. If Ops is running wild, the best processes will sit useless on the mantle and DCMA will be likely be much less impressed with your other approaches.