June 05, 2014

Tips for your Live CPSR

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

1. Communicate your Corporate Story: If you present your company as just another "contractor supporting the warfighter" (a term that is not necessarily impressive to DCMA on its own) you’ll eliminate the ability to take advantage of exceptions to requirements. Example - a contractor who focuses on R&D had a compliance exception - up to $30K – for field procurements in support of R&D projects. The idea was to allow PMs field testing prototypes to purchase replacement parts and components to complete testing. Their CPSR Team Lead was a former SBIR CO and, far from rejecting the practice, suggested that a higher threshold for field purchases could be requested.

If you have a story that explains your approach to file compliance that may differ from "the norm," SELL IT. Begin in your data call, continue in the in-brief and bring it up during every meeting and report (when relevant!). Government understanding of your relative position between Customers and supply chain can do a lot of lessen the impact of findings. During this CPSR the client explained that much of their revenue is derived from support contracts for unique Customer systems. As a result, during the in-brief the Team Lead mentioned that given the contractor's area of specialty the team would not expect to see competitive buys and that their focus would be the validity of source justifications. By telling the story the client walked out of the meeting with Competition off the table as a potential significant finding. That's magical! 

2. Dress Code: SES and Lawyers wear suits; high GS-ers wear jackets and ties (or female equivalent); everyone else wears business casual. I suggest applying that dress code internally during your review. If you wear a suit during your CPSR around the DCMA team you'll be overdressed every day. You'll also be giving the impression (at director level and below) of formality at the institutional level (people wear suits to appear polished). Does your system and its output agree with this impression? Make sure your visual cues agree with your corporate story. If you're a high tech company, DCMA will expect to see engineers running around in jeans and flip flops :)

3. Fighting with the Review Team: Don't. Ever. Even if they are dead wrong (e.g. asking debarment questions on orders under the micropurchase threshold) don't try to dress them down with an encapsulation of the FAR and its legislative history. There may be a time for that (during the draft report and response phase) but it's not during the live review. Just like how a server you insult is 10x more likely to spit (or worse) in your food, an angry analyst is much more likely to eviscerate your files. The deeper they cut the harder it is to heal prior to determination.

4. It Ain't Over Till It's Over! You have three main opportunities to gain purchasing system approval: (a) during the actual review (by avoiding significant findings); (b) during response to the draft ACO report; and (c) during proposal of your Corrective Action Plan (which sets the stage for approval or failure during your next CPSR). Even if the review doesn't go well, every interaction with DCMA should build trust with the team that your company is committed to the process and knows the next steps to achieve compliance. If that gets carried successfully into the response to the draft report, you can get approval even after a relatively disastrous review (see my previous post on the contractor with 22 significant findings who gained approval without a formal CAP due to their response to the draft report).