Providing the greater GovCon community with “real-world” procurement leadership and CPSR compliance expertise in the ongoing pursuit of maintaining government approved purchasing systems.
The Contractor Purchasing System Review (CPSR) provides contracting officers a basis for granting or withholding approval of a contractor’s purchasing system. Expertise in this highly specialized and regulated audit preparation practice is difficult to find.
Our ability to provide customer satisfaction in the ever-changing regulatory environment and unstable CPSR-centric landscape can largely be attributed to one single factor: our people. Capital Edge is unique in the market in that our solution includes former Defense Contract Management Agency (DCMA) CPSR Group personnel, DCMA administrative contracting officers, Government procuring contracting officers and procurement experts who were previously responsible for CPSR compliance while working for major industry players serving DoD, the Intelligence Community and civilian agencies.
Capital Edge employs more CPSR compliance experts than any other firm in the market. A subset of our team previously developed the CPSR criteria directly with DCMA and assisted in the creation of critical tools for DCMA use both during purchasing system reviews and in their FAR Part 44-required system surveillance. Our CPSR SMEs stand out from the CPSR consultant competition because our people have actually negotiated and administered subcontracts/POs for major U.S. Government contractors, in the CPSR environment, prior to their tenure at Capital Edge.
This blend of fully dedicated CPSR experts and their collective experiences ensure the critical perspectives, including the Government reviewer, system approval authority and the Federal procurement practitioner, all of which are directly leveraged for the benefit of our clients.
Our expertise, combined with our CPSR leadership previously serving as “real-world” procurement leaders responsible for ensuring CPSR compliance and maintaining a government approved purchasing system, establishes Capital Edge as the market leader in CPSR readiness and ongoing system compliance for Federal contractors.
In other words, our people are our lifeblood, and our knowledge only begins with DCMA CPSR Guidebook guidance and is honed through the creation and maintenance of a set of proprietary tools developed from our recurring experiences and lessons learned through the DCMA CPSR process. We bring that ground-level experience and solutions to achieve the greatest success for our clients.
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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 system or systems for purchasing and subcontracting…”
According to DCMA CPSR Reports issued in GFY2019, DCMA identified that the “most common material deficiencies” relate 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 amount established in the regulation is discretionary and may be lowered or raised. (FAR 44.303).
The specific subject matter areas evaluated in a DCMA CPSR can be found in the DCMA CPSR Guidebook under the “Major Purchasing Areas” subsection as well as in the associated appendices to the Guidebook.
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.”
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.”
Capital Edge government contract consultants support Government Contractors and Federal Grant Recipients. Our consultants specialize in the regulatory compliance matters you need.
8200 Greensboro Dr #1400
McLean, VA 22102