Benefits
Know weaknesses before the review team
Leverage a mock-CPSR and gap analysis aligned with DCMA frameworks to identify system shortfalls and reposition your organization for success.
- Mock CPSR
- Gap analysis
- Purchasing system design assessment
Get documentation that checks DCMA boxes
Improve, rebuild, or implement off-the-shelf infrastructure that balances compliance and your risk tolerance for a fully adequate purchasing system that sticks.
- Policy & procedure development
- Form & checklist development
Command your review
From DCMA data calls to entrance briefings, shake hands with your command center, offering real-time guidance, mock exercises, and advocacy to position your team successfully.
- DCMA data call response support
- Mock interviews
- System demonstration preparation
- Entrance briefing preparation
- Real-time DCMA liaison
Close findings, open opportunities
Adequately resolve DCMA findings to build your reputation and future-proof your organization to drive self-sufficiency in your next CPSR.
- DCMA questionnaire responses
- Corrective action plan development
- Corrective action plan implementation
- CPSR & procurement training
Related
success stories
Take a deeper dive and discover how we’ve helped clients with Purchasing System Compliance.
FAQs
Can’t find what you’re looking for?
What is a CPSR, and what does it cover?
A CPSR is a comprehensive adequacy evaluation of a contractor’s purchasing policies, procedures, and practices conducted by DCMA under FAR Part 44. Despite being commonly referred to as a “CPSR audit,” the correct term is a “review,” reflecting its broader evaluative scope rather than a transaction-level financial audit. The CPSR covers the full purchasing lifecycle, from requirements generation through subcontract completion, including all purchasing and subcontracting activities as defined under DFARS 252.244-7001. The review assesses whether a contractor’s purchasing system meets government standards for oversight, documentation, competition, and subcontractor management, with the adequacy determination directly affecting contract performance eligibility and competitive standing.
What triggers a CPSR, and what thresholds apply?
A CPSR is initiated on a discretionary basis by the Administrative Contracting Officer (ACO), whose decision is informed by the contractor’s anticipated qualifying sales volume and a risk-based assessment of purchasing system adequacy. Under FAR 44.302, the standard threshold is anticipated FAR Part 44-qualifying sales exceeding $25 million in the next 12 months. For defense contractors, DFARS 244.302 establishes a higher threshold of $50 million in the next 12 months. Importantly, under FAR 44.303, these thresholds are discretionary and may be adjusted upward or downward based on the ACO’s risk assessment. Contractors approaching either threshold should treat CPSR readiness as an active program rather than a future consideration, as review timelines are not always predictable.
Who conducts a CPSR, and how is the review structured?
CPSRs are conducted by the DCMA, specifically the DCMA CPSR Group, operating under the DOW. DCMA personnel who perform CPSRs are designated as analysts, not auditors, a distinction that reflects the evaluative rather than financial nature of the review. The process typically begins with a data call requesting purchasing records, policies, and procedures, followed by an entrance briefing, transaction sampling, interviews with purchasing personnel, and an exit briefing summarizing preliminary findings. The DCMA CPSR Group issues a formal report that serves as the basis for the ACO’s adequacy determination. Understanding this structure allows contractors to prepare each phase deliberately rather than reacting to government requests as they arrive.
What are the most common purchasing system deficiencies identified during a CPSR?
DCMA CPSR reports consistently identify a recurring set of deficiency areas that contractors should address proactively. The most frequently cited include inadequate price and cost analysis documentation, insufficient sole source justification, gaps in commercial item determination (CID) procedures, noncompliance with Truth in Negotiations Act (TINA) requirements under FAR Part 15, deficiencies in debarment and suspension screening, and incomplete or outdated policy and procedure manuals. Reporting obligations under the Federal Funding Accountability and Transparency Act (FFATA) and Defense Priorities and Allocations System (DPAS) requirements are also recurring findings. Contractors who conduct structured gap analyses against these known deficiency categories before a CPSR is initiated consistently enter the review in a stronger and more defensible position.
What are the consequences of a purchasing system disapproval?
A purchasing system disapproval by the cognizant ACO carries consequences that extend well beyond the immediate review cycle. Disapproved contractors face increased government consent to subcontract requirements under FAR 44.201, meaning individual subcontract awards require prior government approval, which slows execution and increases administrative burden. DFARS 252.242-7005 authorizes payment withholding on affected contracts until the deficiency is resolved. Disapproval also triggers disclosure through the Contractor Business Analysis Repository (CBAR), creating reputational visibility across the government contracting community. Combined with the competitive disadvantage in future source selections, a disapproval has compounding consequences that make proactive readiness a materially more cost-effective investment than post-finding remediation.
Where do CPSR requirements come from, and how is the DCMA guidebook used?
CPSR requirements derive from FAR Part 44 and DFARS Part 244, which establish the statutory and regulatory framework for purchasing system adequacy. The operational detail that governs how DCMA analysts conduct reviews is contained in the DCMA CPSR Guidebook, published by DCMA to provide guidance and procedures for evaluating contractor purchasing systems and preparing CPSR reports. The Guidebook’s “Major Purchasing Areas” subsection and associated appendices define the specific subject matter areas evaluated during a review, making it the single most important reference document for CPSR preparation. Contractors who build their policies, procedures, and documentation infrastructure directly against the Guidebook’s evaluation criteria eliminate ambiguity about what adequacy actually requires in practice.
What does purchasing system approval actually mean, and is there such a thing as CPSR certification?
The phrase “CPSR certification” is a misnomer that misrepresents how the process works. A CPSR does not result in a certification. It results in a formal adequacy determination made by the cognizant ACO under FAR 44.305, who holds the sole authority to grant, withhold, or withdraw purchasing system approval. An approved system signals to contracting officers across the government that a contractor’s purchasing infrastructure meets federal standards, reducing friction in future awards and subcontract consent requirements. For contractors pursuing growth through larger, more complex awards, purchasing system approval is a competitive asset that reflects organizational maturity, demonstrates internal control discipline, and supports the broader contractor business system posture that government customers evaluate at every stage of the acquisition lifecycle.
200+ CPSRs, 100% success rate
Partner with experts who have guided over 200 teams to successfully navigate their CPSR, close findings, and build purchasing systems that withstand scrutiny.