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 244.3 Contractor’s Purchasing System Reviews
How does a purchasing system fit into subcontracting plans? Risk tolerance. Not only does your Contracting Officer need to understand that the business partner can handle their responsibilities satisfactorily. They need to know both the prime and the sub possess or will acquire technology that can handle their responsibilities satisfactorily changing of monies that pertains to actions throughout the life-cycle of the contract.
DFARS 243.301 Objective
The Administrative Contracting Officer (ACO) or Senior Contract Specialist in some offices approves the contractor’s purchasing system.
DFARS 243.302 Requirements
A 12 month contract period of $50M or more requires a CPSR.
a DFARS 243.303 Extent Of Review
The ACO must review documentation concerning commercial status as well as the adequacy of the counterfeit electronic part and avoidance system. Essentially, to discern whether the product is authentic and purchased genuinely.
DFARS 243.305 Granting, Approving or Withdrawing Approval/DFARS 243.305-70 Policy
The ACO must accept or reject the system and pursue correction of any deficiencies. Their determination aligns with the clause at DFARS 252.244-7001. The designated Purchasing System Auditor must write a report of their findings. The report shall contain findings, a review, any material weaknesses, allow a vendor response to deficiencies within 30 days and draft a final determination of acceptance or rejection. The vendor must then respond within 45 days as to how any deficiencies are to be corrected. The inability to correct deficiencies can and will result in the withholding of payment to the contractor by the government. Approval is to be made immediately upon notification of corrected deficiencies. The CO shall disperse the determination to all involved parties of the agreement as well as the payment office. The CO must proceed as follows concerning deficiencies; move to negotiate, halt negotiations to have the offeror resubmit their proposal, consider a different contract vehicle, determine how the deficiencies alter the original cost analysis, decide if the correction of deficiencies is a cost reimbursement line-item, reducing the profit or fee percentage or tailor a reopener clause that allows the government to readjust the contract amount after award.
The government needs to be sure that all systems are go before a contract award is made. That includes any subcontractor as well as purchasing technology. The above procedures may be considered to be arduous. Nevertheless, they are necessary to ensure that all business transactions operate smoothly.
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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