Blog Tags - Cpsr

ISO and CPSRs

The DCMA-enforced CPSR requirement that contractors check sam.gov prior to subcontract award has always bothered me. Not because it's not a good business practice, but because contractor sam.gov checks are not a requirement per FAR Part 52.209-6. Because debarment is a public law, a DCMA finding of noncompliance with the (imaginary from a regulatory perspective) sam.gov requirement can lead to system failure without additional findings. 

I'm onsite supporting a CPSR and thought I'd provide a few “outside the file” tips for your next review:

I recently helped a client with their response to DCMA's initial CPSR Report. The report on their then-approved system cited 22 significant deficiencies (six public law) and the Review Team’s disapproval recommendation. This was the bad news. 

The good news is that last week this contractor received notification of approval of their purchasing system with a follow-up CPSR TBD based solely on that response and some follow-up questions. 

What happened? For me, this CPSR highlighted some important aspects of preparation and recovery I wanted to share: 

How are you supposed to respond to questions DCMA submits during the file review portion of the CPSR?  

First, make sure you know what the question actually is. If the substance of your response isn't clear after a few reads, send it to someone else who can give a clean perspective. When you send it, don't give your interpretation and ask for concurrence - let them read, absorb and regurgitate on their own. You're on a deadline, so make sure they know that (if they don't already!)  

Once you have the response set, here's a suggested format for delivery: