If DFAR 252.242-7005 does not apply, can DFAR 252.244-7001 still apply?
Sorry, but your contractor is probably correct. There is not a link (at least not a link such as what you are suggesting) between 252.242-7005 Contractor Business Systems and 252.244-7001 Contractor Purchasing System Administration. You have to look at the “prescription” of each clause. The prescription is the language in the FAR and DFARS that tells the user when a particular clause needs to be put in their contract. This is the DFARS prescription for 252.244-7001:
As prescribed in 244.305-71, use one of the following clauses:
Basic. As prescribed in 244.305-71(a), use the following clause.
CONTRACTOR PURCHASING SYSTEM ADMINISTRATION-BASIC (MAY 2014)
DFARS 244.305-71 says:
244.305-71 Contract clause.
Use the Contractor Purchasing System Administration basic clause or its alternate as follows:
(a) Use the clause at 252.244-7001, Contractor Purchasing System Administration—Basic, in solicitations and contracts containing the clause at FAR 52.244-2, Subcontracts.
(b) Use the clause at 252.244-7001, Contractor Purchasing System Administration—Alternate I, in solicitations and contracts that contain the clause at 252.246-7007, Contractor Counterfeit Electronic Part Detection and Avoidance System, but do not contain FAR 52.244-2, Subcontracts.
This means that you must look to see if your contract contains FAR 52.244-2, Subcontracts. If you have this clause, then your contract must also contain 252.244-7001. (244. 305-71 (b) will not apply because you are not covered by CAS)
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