Capital Edge’s Tip Line #17: The Latest on Contractor Purchasing System Reviews (CPSRs)

Capital Edge Tip Line – April 7, 2026

The Latest on Contractor Purchasing System Reviews (CPSRs) – Edition 17

In this week’s Capital Edge Tip Line, CEO Chad Braley discusses Contractor Purchasing System Review (CPSR) updates following the DoW's adoption of model deviation text tied to the FAR Overhaul in February 2026.

Key Updates from This Week’s Tip Line

What You Need To Know

What’s happening? Updates from the DoW's adoption of model deviation text tied to the FAR Overhaul have impacts to CPSR applicability, definitions, and purchasing thresholds.

What's being discussed? 

1. Definition updates – Several FAR Part 44 definitions were condensed or removed, and the subcontracts definition now explicitly includes intercompany transfers.
2. CPSR eligibility – The longstanding, “unofficial" $25M CPSR threshold for “qualifying sales" has been removed. With the adoption of the RFO, Contracting Officers now can determine CPSR eligibility based on contract volume, complexity, and subcontract dollar value.
3. Purchasing threshold increases – The increase of the micro purchase threshold to $15k and the simplified acquisition threshold to $350k in October 2025 continues to shape purchasing system expectations, with higher thresholds for contingency operations and defense against certain attacks for both inside and outside the U.S.
4. Common deficiencies persist – We continue to see consistent CPSR deficiencies in areas such as, without limitation, price and cost analysis, source selection justification, FFATA, debarment, DPAS, payments to influence, commerciality determinations, CCPD, and policy and procedure deficiencies.

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