In light of: 1. FAR 12.208 Contract Quality Assurance which states that we rely on the contractor's exising QA systems, and; 2. the fact that 52.212-4 Contract T's & C's- Commercial Items para. (a) Inspection/Acceptance does not contain the language comparable to that found in 52.246-4 para (b) which requires an inspection system covering contract services: is not the PWS's requirement for a QCP for commercial services extraneous, adding needlessly to contract complexity and cost? Thank you.
FAR 52.212-4 asserts the Government's right to inspect the services and to take action on nonconforming supplies and services. FAR 52.246-4 provides for what's already in 52.212-4, and adds the requirement that the contractor must establish and maintain its own self-inspection/QA system. The language at FAR 12.208 is for the Government to follow, while the clauses at FAR 52.212-4 and 52.246-4 are for the contractor to follow (contractors don't follow the FAR per se). Even if the performance work statement (PWS) requires the contractor to submit a quality control plan (QCP), technically it could do so without establishing and maintaining a self-inspection/QA system. Even though the Government would like to assume that a QCP means that the contractor must in fact have an internal QA system, you could have the former without the latter...though admittedly it wouldn't make much business sense.
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