A reliable purchasing system is essential to your ability to be cost competitive and make appropriate purchasing and subcontracting decisions. Our company will serve as your accounting and government regulation compliance experts to ensure that your Purchasing System complies with system criteria recently implemented by the Department of Defense (DoD), and certain civilian agencies such as the Department of Energy and National Aeronautics and Space Administration (NASA).
Our objective is to ensure that your company has a fully compliant purchasing system that consistently results in cost effective purchasing practices and subcontract management and will pass a Government mandated Contractor Purchasing System Review (CPSR) when required. We can help ensure your purchasing system provides for appropriate price and cost analysis and subcontractor/vendor selection that results in sound purchasing decisions and mitigates the risk of both government audit exceptions and withholdings from progress payments and contract billings for failing to comply with newly implemented regulations. DFARS regulations governing purchasing system requirements have become more and more complex. To be acceptable, DFARS 252.244-7001 currently requires a purchasing system to meet 24 separate criteria including:
- An adequate system description including policies, procedures, and purchasing practices that comply with the Federal Acquisition Regulation (FAR) and the Defense Federal Acquisition Regulation Supplement (DFARS);
- Use of competitive sourcing to the maximum extent practicable, and ensure debarred or suspended contractors are properly excluded from contract award;
- Evaluation of price, quality, delivery, technical capabilities, and financial capabilities of competing vendors to ensure fair and reasonable prices;
- Timely and adequate cost or price analysis and technical evaluation for each subcontractor and supplier proposal or quote to ensure fair and reasonable subcontract prices;
- Ensuring the proper type of contract selection and prohibiting issuance of cost-plus-a-percentage-of-cost subcontracts;
- Maintaining subcontract surveillance to ensure timely delivery of an acceptable product and procedures to notify the Government of potential subcontract problems that may impact delivery, quantity, or price;
- Enforcing adequate policies on conflict of interest, gifts, and gratuities, including the requirements of 41 U.S.C. chapter 87, Kickbacks;
- Performing internal audits or management reviews, training, and maintaining policies and procedures for the purchasing department to ensure the integrity of the purchasing system; and
- Establishing and maintaining policies and procedures to ensure purchase orders and subcontracts contain mandatory and applicable flowdown clauses, as required by the FAR and DFARS, including terms and conditions required by the prime contract and any clauses required to carry out the requirements of the prime contract, including the requirements of 252.246-7007, Contractor Counterfeit Electronic Part Detection and Avoidance System, if applicable;
Redstone Government Consulting has the unparalleled expertise, including over 160 years of senior level DCAA experience, needed to ensure your purchasing system complies with DFARS 252.244-7001 and other FAR and DFARS regulatory requirements.
Some of the services we provide to meet your purchasing system compliance needs include:
- Designing and/or implementing a new tailored Purchasing System, or updating the existing system for process improvements.
- Preparing written Purchasing System policies, procedures, and detailed staff instructions.
- Development and delivery of customized Purchasing related staff training.
- Risk assessments and GAP analysis of your current purchasing policies, procedures, and practices.
- Mock audits of your purchasing system using procedures that mirror DCAA/DCMA procedures for evaluating contractor purchasing systems.
- Developing and implementing appropriate corrective action plans.
- Responding to DCAA/Independent CPA audit findings and contracting officer inquiries.
- Advice and assistance to supplement, as needed, internal compliance department knowledge and expertise.
- Strategic planning assistance.