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Who should attend:

This course is designed for professionals in the disciplines of compliance, finance, accounting and mid-high level contracting positions with responsibilities related to supply chain management, purchasing and delivery.

What you will learn:

This course outlines and explains the components of a compliant Contractor Purchasing system. It provides insight into the requirements of an adequate purchasing system; the design of an effective purchasing system; the monitoring of a system; the support of Government audits; and how to prepare and respond to a purchasing system review.

Through a discussion and participative methodology, the course will include coverage of: the prime and subcontractor relationship; consent requirements; thresholds; types of contracts; advance notification requirements; contracting officer evaluations; considerations; review objectives; regulations requirements; extent of review; surveillance; approvals; responsibilities; notifications; disclosures; reports.

Dates and Locations

This course will be scheduled soon. Please enter your information below to receive a notification when the class is scheduled.

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DAILY SCHEDULE
8:00 AM - 3:00 PM
La Jolla, Hilton Head and Las Vegas September Weeklong Conference Locations
9:00 AM - 4:00 PM
Schedule for All Other Locations

Course Curriculum

1. Background of Contractors' Purchasing System Requirement

  1. Why the Government is concerned
  2. Applicability of purchasing systems
  3. Contract type considerations
  4. Impact of inadequate purchasing system

2. Requirements for Formal CPSR (Contractors' Purchasing
System Review)

  1. Thresholds for review
  2. Three year requirement
  3. Subcontract types evaluated in CPSR
  4. Contracting officer cognizance
  5. Government auditor (e.g. DCAA) involvement
  6. Other Government purchasing system audits
  7. Audit planning and preparation


3. Subcontract Consent and Advance Notification
Requirements Under FAR

  1. Background
  2. CPSR opinion impact on requirements
  3. Guidelines for preparing consent documentation
  4. Potential impact of not obtaining required Government
    consent


4. CPSR Criteria Under FAR

  1. Degree of competition
  2. Pricing policies and techniques
  3. Methods to evaluate subcontractor responsibility
  4. Treatment of affiliates and partners
  5. Policies and procedures pertaining to small business
  6. Planning, award and post-award management
  7. CAS compliance requirements
  8. Appropriateness of subcontract types
  9. Management control systems


5. Government Surveillance

  1. Government reporting requirements to contractor
  2. Disclosure of subcontract CPSR approval status to prime
  3. Granting approval
  4. Withholding or withdrawal of approval
     Cost or pricing data
     Implementation of CAS
     Advance notification
     Small business subcontracting


6. Cost Analysis of Proposed Subcontract

  1. Applicability
  2. Guidelines for performing cost analysis


7. Price Analysis of Proposed Subcontract

  1. Applicability
  2. Guidelines for performing price analysis



8. Government Purchasing Fraud Risk Indicators

  1. Incurred cost audits (kickbacks)
  2. Defective pricing audits (intentional overpricing)
  3. Make or buy decision changes (intentional overpricing)


9. Purchasing System Internal Control Structure

  1. DCAA internal control matrix
     Contractor compliance - training, policies and procedures
     Purchase orders and subcontract clauses
     Management of purchasing
     Selecting sources
     Pricing and negotiation
     Subcontract award and administration
  2. Contractor control environment impact to audits
  3. Leveraging SOX (Sarbanes-Oxley) purchasing internal control
    documentation
  4. Influencing scope of Government audits


10. Subcontract Management

  1. Socioeconomic considerations, prime contractor obligations
     Subcontractor obligations
     Liquidated damages
     EEO (Equal Employment Opportunity) pre-award clearance
  2. Preparation for on-site visit
     Entrance conference
     Working space
     Random purchase order audit
     Exit conference
  3. Audit protocol
     Preparation of personnel
     Liaison responsibilities
     Answering questions
     Real-time fixes
  4. Financing
  5. Subcontract closeout

Jean Labadini
Jean Labadini has 40 years of experience in Government contracting, 35 of which were spent with the Defense Contract Management Agency (DCMA) – retiring as the Director of the CPSR Group.  
Professional Experience: Jean has spent her post retirement years supporting defense contractors in need of her expertise in purchasing systems pre and post CPSR, and as an instructor for the Federal Publications CPSR Course.   In her role as Director of the CPSR Group with the DCMA, Jean led the group of Procurement Analysts in performing their mission to review contractor purchasing systems. Jean personally participated in reviews; developed and provided training to each of the CPSR Hub sites; drafted a Guide to Planning and Conducting CPSRs, and DCMA Work Instructions associated with Advance Notification and Consent. Jean has also served as an Administrative Contracting Officer (ACO), a Divisional Administrative Contracting Officer (DACO), and a Systems Administrative Contracting Officer (SACO).
Jean maintains expert level knowledge in acquisition regulations (FAR, DFARS) and is knowledgeable in Cost Accounting Standards (CAS). She has extensive experience in contract negotiations and in conducting business system adequacy determinations. Jean is well versed in DCMA tools (MOCAS, SDW, CAFU) and has performed cradle to grave contract management - from contract receipt/review to contract closeout. Jean has administered contract financing provisions associated with progress payments and public vouchers.
John Van Meter
John Van Meter has over 30 years of experience in government contracting.  John brings a unique perspective of industry and consulting experience to contract compliance, internal control and business process development engagements. John’s experience includes cost accounting, pricing, internal auditing and subcontract management.  John also is an accomplished speaker and trainer within the government contracting industry.

Professional Experience: John spent much of his career with KPMG, where he was responsible for managing the firm's Government Contractor Advisory Services practice delivering professional services to premier clients worldwide. He led advisory projects providing federal contract compliance, regulatory compliance including Sarbanes-Oxley 404 internal control assistance, business system implementation and internal audit outsource services. Before that, John had cost accounting, pricing, internal auditing and subcontract management positions with Northrop Aircraft and the Garrett Engine Company.
John is a frequent speaker for industry and professional associations (e.g., Association of Government Accountants, Government Contractor Training Institute Inc., Federal Publications Seminars and National Contract Management Association). He has developed and is currently a presenter of the Federal Publications Seminars Contractor Purchasing System Reviews (CPSR) and Internal Control Practices for Federal Contractors courses. 
John is also a primary trainer for the Government Contractor Training Institute (GCTII) in La Jolla, CA and has developed and delivers courses on DoD Business Systems Compliance, Fundamentals of Government Contracts, Cost Accounting Standards and others.  In addition, he has served as an author for numerous publications.
Michael Carter
Michael is a Senior Consultant with Capital Edge Consulting, Inc. and a member of the firm’s CPSR Compliance Practice. He is an expert in the Defense Contract Management Agency (DCMA) Contractor Purchasing System Review (CPSR) process.
Michael’s areas of expertise include contractor business systems compliance, with an emphasis in DCMA CPSR readiness, execution, and compliance. He is also versed in FAR and DFAR regulations, DCMA processes and procedures pertaining to purchasing system reviews and contract administration, Cost Accounting Standards (CAS), Earned Value Management Systems (EVMS), proposal analysis and evaluation, cost modeling and estimating, forward pricing rate recommendations (FPRR) and agreements (FPRA), and he is fluent in Spanish. Michael has experience conducting CPSR-related training to DCMA CPSR Group procurement analysts as well as to dozens of Federal contractors.

Professional Experience: As a DCMA CPSR Procurement Analyst, Michael was the “Team lead” for nearly 15 DCMA CPSRs in the last 3 years and served as the procurement analyst in nearly 15 additional reviews during the same time period. Michael was one of the few procurement analysts with experience in reviewing small business concerns and Ability One contractors.  His experience covers a complete spectrum of contractors from A&E service providers to foreign manufacturing firms. During his tenure as a DCMA CPSR Group Procurement Analyst, Michael developed a tool for use by all CPSR Group procurement analysts (for all four CPSR Teams) in performing CPSRs. Also, Michael developed a tool that all DCMA Administrative Contracting Officers (ACO) are currently required to use in their annual surveillance of contractor purchasing systems responsibilities. Michael was personally selected by the DCMA CPSR Director to represent the Phoenix CPSR Team at the National Contract Management Association (NCMA) World Congress (2015). 
MEET YOUR CONTINUING EDUCATION CREDIT REQUIREMENTS
SEE INDIVIDUAL COURSES FOR AVAILABLE CREDITS
Certificates of Completion are provided to all seminar participants who attend Federal Publications Seminars courses following the event, upon request.
NCMA: CONTRACT MANAGER CERTIFICATION
All Federal Publications Seminars courses meet the course requirements of the National Contract Management Association’s certification programs. We are a proud Education Partner of the NCMA.
CPE: CONTINUING PROFESSIONAL EDUCATION
Federal Publications Seminars is part of West Professional Development, which is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org.
CPE HOURS
This Program is eligible for: 13.0 (CPE) hours of credit
Program Level: Basic
Program Prerequisite: None
Advance Preparation: None
Method: Group-Live
CLP: CONTINUOUS LEARNING POINTS
APPROVED FOR CLP BY
DEFENSE ACQUISITION UNIVERSITY
Defense Acquisition Workforce members must acquire 80 Continuous Learning Points (CLP) every two years from the date of entry into the acquisition workforce for as long as the member remains in an acquisition position per DoD Instruction 5000.66. We will provide you with documentation of points awarded for completing the event.
CLP HOURS
This Program is eligible for: 11.0 (CLP) hours of credit
CLE: CONTINUING LEGAL EDUCATION
States have widely varying regulations regarding MCLE credit. LegalEdcenter is an approved provider in AL, AK, AR, CA, GA, IL, ME, MO, MS, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, PA, RI, SC, TN, TX, UT, VA, VI, VT, WA, WI, and WV. Credit may be applied for in other jurisdictions on request and in accordance with state MCLE rules.
** Please note that because some states are changing their policy on CLE reporting, you will need to fill out the request for credit from Federal Publications Seminars within 10 business days, or we may not be able to issue credits for the program.
CLE HOURS
This Program is eligible for: 11.0 (60 minutes), 13.0 (50 minutes)
100
Basic or fundamental subject matter is covered. Courses are geared to general knowledge or can be taken as a refresher.
200
Specific topics or issues within a topic area are covered. Students should be familiar with terms of art and general concepts concerning the course topic.
300
Workshops and class discussions cover specific subject matter in-depth, and participation is strongly encouraged. Attendees should have at least 2-3 years' experience in the area of study.
400
Courses build upon students' knowledge and experience, and cover complex issues within the subject matter. Should have 4-5 years' mastery of subject for in-depth analysis.
500
Masters-level programs designed for professionals with 5+ years' experience. Courses cover in-depth and technical analysis on specific subjects and updates on current issues.
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Contractors' Purchasing Systems Review
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