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    As a defense subcontractor we are seeing an increase in some Primes submitting RFQ's and PO's with a large Qty on one Line Item and reflecting multiple USG Contract Numbers, Programs, and Flowdown documents. My response to these Primes is they must provide the Qty/$ associated by USG Contract Number and Flowdown, preference is each USG Contract and Qty be separate Line Items on their RFQ and PO. I am receiving pushback from the Primes stating they are managing the individual contracts "behind the scenes" via their Financial/Accounting teams and they are not required to do this. In addition, our internal requirement has been our sales support team enter each of these requirements (Qty, PN by USG Contract and Rating) separately in our ERP system as we need to ensure all applicable flowdowns occur (by contract), manage the DPAS rated contracts (not all are rated, so our customer and sales teams want to select the highest rating for the entire quantity) individually to ensure compliance, and not drive our factory or supply chain to meet DPAS when not applicable. In summary, my input to both the Prime and our internal teams, as a defense subcontractor we are obligated to: * Review and accept only the applicable FAR-DFARs by the individual USG Contract, value, effort and rating * Flowdown applicable clauses to any subtier subcontractor and our internal supply chain teams, by individual USG Contract, value, effort, rating * Ensure compliance, and on-time delivery, DPAS rated requirements by individual USG Contract * Be able to support an audit by DCMA/DCAA that reflects we have met the above I cannot find anything specific (in layman's terms!) that supports the above. I have a internal call today to further discuss, and any information or feedback would be truly appreciated. Thank you Candy


    Answer

    Regarding the first two bullets of your "guidance and input to your Prime and Internal Team on your obiligation to..."  we provide the following:

    Depending on the contract, there might be clauses that you must accept and flow down to your subcontractors.  These are identified in the clause or provision itself depending on things such as the dollar amount, contract type, or what is being procured (e.g. see the wording at FAR 52.203-15(b) or 52.209-6(e) for examples on how this language might be written).  Then there are clauses you could choose to accept or flow down depending on your corporate policy.  But remember, if you are a subcontractor the government has no privity of contract with you.

    Regarding the 3rd bullet:

    If your contract (prime or subcontract) is subject to have a rated order issued, then the solicitation should have included the provision at FAR 52.211-14 and the clause at 52.211.15.  These identify and detail your requirement.

    Regarding your 4th and last bullet:

    Nowhere in the FAR or DFARS could we find language mandating that RFQs or Purchase Orders from a prime to a subcontractor must specify and separately identify quantity and dollar amount by the prime USG contract number (nor did we expect to find that).

    The best citation we can provide to review guidance on auditability and contractor business system compliance and acceptance is DFARS 242.7001.  We chose this because it has a link to each clause that covers the various contractor business systems your question may involve.  Each individual clause provides an overview of what the contractor business system must be capable of doing.  The prescription for each of these clauses will tell you whether it should be in your contract with the prime and whether or not you need to flow it down to your subcontractors.

    We hope this helps your situation.

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