A question on performing a Property Management System Analysis (PMSA) on a Subcontractor. I understand that a Federal auditor can be granted permission to access a subcontractor’s facility by the prime contractor. With access to the subcontractor's facility granted by the prime contractor can the Federal auditor then perform a PMSA on the subcontractor or does privity to contract come into play?
Per FAR 52.245-1(f)(1)(v) Subcontractor control, the prime contractor is required to establish and implement a procedure to periodically review its subcontractor’s property management system for adequacy. Therefore, the property administrator typically only audits the prime contractor’s property management system to ensure that the prime contractor is compliant. This is consistent with FAR 42.202(e)(2), which states the prime contractor is responsible for managing its subcontracts and the review of subcontracts by the contract administration office is normally limited to evaluating the prime contractor’s management of subcontracts. It further states that supporting contract administration shall not be used for subcontracts unless the following exceptions apply:
- The Government otherwise would incur undue cost;
- Successful completion of the prime contract is threatened; or
- It is authorized under paragraph (f) of this section [FAR 42.202] or elsewhere in this regulation [Federal Acquisition Regulation].
Basically, the property administrator should not perform a subcontractor PMSA unless one of the exceptions applies. It is suggested that you check for additional policy/guidance provided by your agency.