Our CPSR is coming up and we are wondering if this contract would be excluded? Based on FAR 44.3 Competitive FFP is excluded, but this contract is a hybrid. Thanks!
The CPSR team may review purchase actions associated with the cost reimbursable CLINs of a contract that is predominantly FFP. Sampling is done of purchase orders and subcontract files, so the sample may be at the CLIN level rather than at contract level. There is a good reason for this. If a contractor thought that cost reimbursable CLINs in a FFP contract would not be subject to review, there would be less motivation to follow effective purchasing controls for those types of CLINs. The CPSR team will want to ensure effective controls are being used for all cost reimbursable CLINs, regardless of whether they are "buried" inside a hybrid contract.
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