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  • Question

    Are there any lessons learned from recent industry CPSR actitivity or any knowledge on what auditors are focusing on this year?


    Answer

    A quick internet search of four selected DoD websites where it seemed possible to find CPSR lessons learned did not yield any documents showing a compiled list of CPSR lessons learned (i.e., dap.dau.mil; acc.dau.mil; dcma.mil; and dcaa.mil).  DCMA does have policy guidance and a guidebook that can be accessed on its webpage (dcma.mil) and DCAA does have audit programs and internal procedures that are accessible on its web site (dcaa.mil).
    A quick Google search for “CPSR lessons learned” returned a number of blogs, articles and other documents that might provide useful lessons learned information.

    Somewhat recently (starting with an interim rule dated May 2011), the DFARS was modified to implement the “DoD Business System Rule.”  To understand the Rule as it relates to a DoD contractor Purchasing System a study of the “new” (more accurately, “newer”) DFARS standard clause
    252.244-7001 (CONTRACTOR PURCHASING SYSTEM ADMINISTRATION (MAY 2014)) and DFARS standard clause 252.242-7005 (CONTRACTOR BUSINESS SYSTEMS (FEB 2012)) is fundamental.  The DFARS can be found at: http://www.acq.osd.mil/dpap/dars/dfarspgi/current/index.html.
     
    Two highlights of DFARS 252.242-7005 / DFARS 252.244-7001 are: (1) A list of 19 Purchasing System criteria that must be meet by the system; and (2) mandatory withholding of payments to the contractor by the Government Contracting Officer when/if a contractor System is disapproved by the assigned Administrative Contracting Officer.  As far as the focus is concerned, this process is somewhat new, so the 19 criteria come to mind.

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