What contract professionals must know about Contractor Purchasing Systems and CPSRs Designed especially for Purchasing, Finance and Accounting Managers; Contract Compliance Professionals; and Government Contract Attorneys
Course Curriculum
1. Background of Contractor Purchasing System Requirement
- Why the Government is concerned
- Applicability of purchasing systems
- Contract type considerations
- Impact of inadequate purchasing system
2. Requirements for Formal CPSR (Contractor Purchasing
System Review)
- Thresholds for review
- Three year requirement
- Subcontract types evaluated in CPSR
- Contracting officer cognizance
- Government auditor (e.g. DCAA) involvement
- Other Government purchasing system audits
- Audit planning and preparation
3. Subcontract Consent and Advance Notification
Requirements Under FAR
- Background
- CPSR opinion impact on requirements
- Guidelines for preparing consent documentation
- Potential impact of not obtaining required Government
consent
4. CPSR Criteria Under FAR
- Degree of competition
- Pricing policies and techniques
- Methods to evaluate subcontractor responsibility
- Treatment of affiliates and partners
- Policies and procedures pertaining to small business
- Planning, award and post-award management
- CAS compliance requirements
- Appropriateness of subcontract types
- Management control systems
5. Government Surveillance
- Government reporting requirements to contractor
- Disclosure of subcontract CPSR approval status to prime
- Granting approval
- Withholding or withdrawal of approval
• Cost or pricing data
• Implementation of CAS
• Advance notification
• Small business subcontracting
6. Cost Analysis of Proposed Subcontract
- Applicability
- Guidelines for performing cost analysis
7. Price Analysis of Proposed Subcontract
- Applicability
- Guidelines for performing price analysis
8. Government Purchasing Fraud Risk Indicators
- Incurred cost audits (kickbacks)
- Defective pricing audits (intentional overpricing)
- Make or buy decision changes (intentional overpricing)
9. Purchasing System Internal Control Structure
- 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 - Contractor control environment impact to audits
- Leveraging SOX (Sarbanes-Oxley) purchasing internal control
documentation - Influencing scope of Government audits
10. Subcontract Management
- Socioeconomic considerations, prime contractor obligations
• Subcontractor obligations
• Liquidated damages
• EEO (Equal Employment Opportunity) pre-award clearance - Preparation for on-site visit
• Entrance conference
• Working space
• Random purchase order audit
• Exit conference - Audit protocol
• Preparation of personnel
• Liaison responsibilities
• Answering questions
• Real-time fixes - Financing
- Subcontract closeout
The Course Faculty
John Van Meter
Mr. Van Meter is a Managing Director in the Government Contractor Services practice of Navigant Consulting, Inc., and resides in the firm’s Vienna, Virginia and Palo Alto, CA offices. He has over 25 years of experience in government contracting and consulting. Mr. Van Meter 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 assistance, business system implementation and internal audit outsource services. In addition to Mr. Van Meter’s public accounting regulatory and compliance experience, he has worked with Northrop Aircraft, Garrett and The Oeco Corporation in accounting, pricing, internal audit and subcontract management positions.
John Dyer
Mr. Dyer is the founder and owner of a CPA firm focusing on assisting clients in managing their business risks and regulatory compliance requirements. He has extensive qualifications working with entities doing business with the public (government) sector. His firm’s primary services are government contract accounting consulting and Sarbanes-Oxley (SOX) Section 404 consulting. Prior to starting his firm, Mr. Dyer, was a Senior Manager with KPMG’s Government Contractor Practice. While with KPMG, he managed significant Government Contract Compliance projects with large defense contractors. One of his projects included evaluating the purchasing system for a large defense contractor performing work in the Middle East. Mr. Dyer was also an instructor of Managerial Accounting at MiraCosta College, and a Senior Auditor with the Defense Contract Audit Agency (DCAA). He has a masters degree from San Diego State University, a bachelors degree from Humboldt State University, is a CPA and a member of the American Institute of CPAs (AICPA) and National Contract Management Association (NCMA).