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  • Question

    Please clarify the requirement for contractors having to continue to perform site surveillance of its subcontractors' PMS even when there is SPA delegation in place.


    Answer


    A prime contractor has a contractual requirement to perform subcontract control under the Government Property clause at FAR 52.245-1(f)(1)(v) and relevant written property management system (PMS) procedures on subcontractor control.  A similar requirement for subcontractor control also exits under the Contractor Purchasing System (CPS) Administration clause at DFARS 252.244-7001(c)(14) and relevant written CPS procedures on subcontractor control.
     
    The existence of a Government property Support Property Administration (SPA) Delegation in no way relieves the prime contractor of any of its surveillance responsibilities unless otherwise agreed to by their cognizant Government property administrator (PA) and documented in both PMS and CPS procedures.
     
    Clearly the prime contractor has responsibility to control their subcontractors, including insight into their PMS.  Even with a SPA in place, this responsibility remains resolute. 
     
    That said, if you feel there is either duplication or overlap of administrative surveillance of your subcontractors with Government property administrators at those locations, identify those instances and enter discussions with your cognizant PA and your cognizant CAO to possibly eliminate them and revise your PMS procedures accordingly!
     
     
    References:
    As noted

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