The Contractor Purchasing System Review (CPSR) commonly referred to by some as a “CPSR Audit” or a “CPSR Review“, is the Government’s evaluation of the effectiveness with which the contractor complies with certain public law, regulations and contract requirements in their policies, procedures and procurement and subcontracting activities. Because the CPSR is ultimately an evaluation of the adequacy of the policies, procedures and practices reviewed, a successful CPSR experience and outcome is never a forgone conclusion.
This is where Capital Edge comes in – our CPSR compliance services are performed by a group of CPSR compliance subject matter experts (SME) committed to helping you prepare for, traverse, and recover from your next CPSR. Our personnel are directly aligned with your objective – securing an approved purchasing system (colloquially known as a “CPSR certification”) and maintaining CPSR compliance.
Our approach to contractor purchasing system compliance has always been “one size does not fit all”; rather, make the public laws and contractual and regulatory requirements work for your business operations and existing internal processes and practices. This practical approach has become the cornerstone of our reputation and yields positive results for our clients. We can help you prepare for, successfully navigate the review and sustain your CPSR compliance posture prospectively, while your purchasing function remains an operationally efficient and customer-focused organization.
Navigating a Contractor Purchasing System Review (CPSR) can be overwhelming without expert guidance. Whether you're preparing for your first CPSR or responding to a recent audit finding, our team is here to assist your purchasing system meets all DFARS requirements and withstands the scrutiny of a DCMA review.
A CPSR evaluates the efficiency, compliance, and internal controls of your purchasing system to ensure it aligns with FAR and DFARS regulations. Failure to meet CPSR standards can result in significant business risks, including loss of approved purchasing system status and reduced competitiveness on government contracts.
Contractor Purchasing System Review (CPSR) requirements are designed to ensure your purchasing system complies with federal regulations and supports responsible use of government funds. Capital Edge Consulting helps contractors prepare for CPSRs by aligning policies, procedures, and documentation with DFARS guidelines—reducing risk and ensuring audit readiness.
Capital Edge’s CPSR-focused support services are wide-ranging and highly customizable to meet the requirements, constraints, and goals of each client. The following is a representative sample of some of the CPSR solutions and areas of support we provide to our clients.
CPSR stands for Contractor Purchasing System Review and is commonly referred to by some as a “CPSR Audit” or “CPSR Review”. In layman’s terms, a CPSR is an adequacy evaluation of a contractor’s policies, procedures and practices against certain FAR and DFARS requirements.
Per FAR Part 44, the CPSR means a complete evaluation of a contractor’s purchasing of materials and services, subcontracting and subcontract management from requirements through completion of subcontract performance.
Although the CPSR is codified in FAR and is therefore not exclusively a DoD contractor concern, the Defense Contract Management Agency (DCMA) employs a team of dozens of CPSR procurement analysts to conduct the reviews of contractors’ purchasing systems. No other federal agency or department is comprised of such a large team of people solely dedicated to performing CPSRs. In fact, civilian agencies commonly engage the DCMA to perform reviews of contractors’ purchasing systems on their behalf.”
The DCMA has defined the Contractor Purchasing System Review (CPSR) Group’s mission – “Ensure that [Government] suppliers’ have purchasing systems in place that contribute to effective subcontract management. Effective subcontract management includes the development of, as well as performance to internal policy and procedures, public law and adequacy of cost and price analyses performed on subcontractors.”
Consistent with this mission statement, the Federal Acquisition Regulation (FAR) CPSR objective in Subpart 44.3, Contractors’ Purchasing System Reviews, states that the “objective of a contractor purchasing system review (CPSR) is to evaluate the efficiency and effectiveness with which the contractor spends Government funds and complies with Government policy when subcontracting….”
Understanding DCMA’s CPSR meaning, mission, and objective, contractors must realistically evaluate their current purchasing system. As part of this evaluation, contractors should use the primary authoritative regulations and DCMA guidance around the CPSR, including, without limitation:
Here are the latest questions being asked about CPSR
Yes. Except for certain transactions excluded under FAR 44, your purchasing and subcontracting activities are within CPSR scope. DFARS 252.244-7001 defines the purchasing system to include the “…the system or systems for purchasing and subcontracting…”
According to DCMA CPSR Reports issued in GFY2019, DCMA identified that the “most common material deficiencies” related to:
A DCMA purchasing system disapproval can cause many issues for a contractor, including:
A CPSR is performed on a discretionary basis, if deemed necessary by the Administrative Contracting Officer (ACO). The ACO’s decision to determine the need can be, in part, influenced by the contractor’s anticipated FAR-44 qualifying sales volume and results of the contractor risk assessment.
Caution: The CPSR dollar threshold is discretionary and may be lowered or raised. (FAR 44.303).
The Contractor Purchasing System Review (CPSR) Guidebook is published by the DCMA. The purpose of the DCMA Guidebook is to provide “…guidance and procedures to Government personnel for evaluating contractor purchasing systems and preparing the CPSR reports.”
Click-to-see the 2021 Revised CPSR Guidebook
The phrase “CPSR certification” is a misnomer. Rather, a CPSR is a review conducted by the government that results in a report which provides the basis, at least in part, for the cognizant federal agency official to make a decision – e.g. that the system is acceptable and approved. FAR 44.305 is very clear as to who has purchasing system approval authority – “The cognizant ACO is responsible for granting, withholding, or withdrawing approval of a contractor’s purchasing system.”
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