Quick Hitter: DFARS Part 232

Just as with my Quick Hitters on the FAR and GSAR, my Quick Hitter series on the DFARS is meant to simplify contracting business with the government. This time with DoD.

DFARS 232.072 Financial Responsibility Of Contractors

A CO must take financial responsibility especially serious. Such determines that contract performance is the largest possible deterrent to successful project completion.

Required Reviews

A review must be conducted when competent fiscal responsibility is unable to be prescribed in an uncomplicated manner through instances such as past performance within the arenas of commercial business as well as federal contracting. Such a review shall be conducted in the pre-award phase. Instances that trigger a review may include a company’s placement on a pre-award or other clearance placement list, the contractor is placed on the hold-up list which means a current or perspective contractor displays current debt with the federal government, the contractor receives assets from the federal government such as contract financing or GFP, the contractor is experiencing unsatisfactory performance on other government work or the proposed product or offeror is new to DoD or the government. Other periodic intervals which trigger review are findings of the previously mentioned items such as (a)(2)-(a)(5) and any other question which proposes a hindrance to contract completion.

Appropriate Information

The CO possesses the authority to request pertinent information in an effort to satisfy a determination of fiscal responsibility. The offeror must comply in a timely manner to ensure a favorable decision. The CO must secure materials which alleviate any concerns pertaining to such. The CO’s request must be generated to and received from an established POC. Examples include, but are not limited to a balance sheet and income statement with a forecast if applicable up to and including the duration of the contract as written in the posted solicitation which are endorsed by a certified public accountant, a technical proposal including corporate history and vitae of public officers of the company, a complete financial history including all affiliations of the company, its officers,top shareholders, a financial forecast which displays current contracts and offers, indirect cost projections, available cash, eradication and exposure to financial crisis as well as creditor history, all tax history, financial agreements including insurance and relevant ffinancial ratios. The CO possesses the liberty to be creative based upon their individually accumulated knowledge and expertise

Cash Flow Forecast

Multiple years up to the current year and subsequent years corresponding to the duration of the solicited contract are essential to the past, present and future cash flows for purposes of comparison. These forecasts must include the origin and use of cash within the corresponding department associated with contract performance. Said forecast(s) must include examples of a fiscal crisis, provide the trail of audit and its rationale, proper estimates which displays proper time frame, materials, production schedules, all payments as well as all receipts.

The CO may consult with the contractor or offeror, SMEs within the government and supply, loan or credit sources to verify and decide on the provided history and forecasts.

I’ve met many COs within our federal government that flex their authority by asking for such materials while neglecting to thoroughly peruse the provision(s). I made it a habit to stump for my vendors in determining their fiscal responsibility to my chain of command in order that they may receive an opportunity to perform their expertise to aid in the service of our nation. To do such one must have a novice working knowledge of these documents and a willingness to extract all provided information. I always notified my vendors that nobody wins if a decision to move forward with no intent to award is made because that just made more work for me. I followed that up by telling them that if I was going to do paperwork I would rather do paperwork for them which granted them an opportunity which could lead to an opportunity to succeed.

I I have no problem doing the same for you.

If you think I can help you then email nicholas.s.robertson@outlook.com for your introductory email and free consultation. 

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