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COVID-19 and Updates on FPS Courses and Events
Some previously scheduled classroom courses and weeklong events from mid-March through May 31 are being offered as Virtual Courses beginning in April. Check our schedule often; we’re constantly adding more.

FPS is planning to move forward with all FPS classroom courses and weeklong events scheduled for June, 2020 and beyond - see website. We want to emphasize that our future plans are incumbent upon the safety and well-being of our customers, staff, and vendors.

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.

Learning Objectives:
Upon completion of this course you will be able to:

  • Recognize the government’s role in the review
  • Demonstrate the ability to recognize different contract types
  • Determine if a purchasing system is inadequate
  • Ability to request and perform a technical analysis
  • Determine correct clauses related to a CPSR
  • Respond to a CPSR Audit 
  • Develop a price and/or cost analysis for a CPSR
  • Demonstrate ability to flowdown clauses to subcontractors
  • Analyze related purchasing events and activities
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.

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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8:00 AM - 3:00 PM
La Jolla, Hilton Head and Las Vegas September Weeklong Conference Locations
8:00 AM - 3:00 PM
Orlando, FL
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

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
  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


Michael Carter
Michael is a Senior Manager 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). 
Stephen "Chase" Kunk
Stephen “Chase” Kunk is Partner / Vice President, Contracts & Procurement at Capital Edge Consulting. Chase specializes in U.S. Government contract and subcontract negotiations, administration, management and purchasing system compliance. His expertise stems from his legal education, former certification as a National Football League contract advisor to professional athletes, and in-depth experience as a contracts and procurement administration manager for an international contractor serving Department of Defense (DoD), Intelligence Community (IC) and civilian agency customers. Chase is a frequent lecturer at Federal Publication Seminars and the Public Contracting Institute on a variety of U.S. Government contracts matters.

Chase’s support to Capital Edge Consulting clients is predominantly in the areas of contract and subcontract administration, purchasing system compliance and Contractor Purchasing System Review (CPSR) readiness and risk mitigation. His exceptional understanding of the federal procurement regulations, and ability to provide value-add advocacy for client’s during audits and negotiations, has directly resulted in numerous approved business systems and definitization of Government contracts that achieved the client’s profit goals. He also leads all contract and subcontract negotiation and administration for Capital Edge Consulting’s internal business operations. 
Certificates of Completion are provided to all seminar participants who attend Federal Publications Seminars courses following the event, upon request.
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.
Field of Study: Specialized Knowledge
Delivery Method: Group-Live Classroom
Federal Publications Seminars is affiliated with West Professional Development and 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 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:
For more information regarding administrative policies such as refunds, cancellations and complaints, please contact Federal Publications Seminars at 888.494.3696.
This Program is eligible for: 13.0 (CPE) hours of credit
Program Level: Intermediate
Program Prerequisite: None
Advance Preparation: None
Method: Group-Live
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.
This Program is eligible for: 11.0 (CLP) hours of credit
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.
This Program is eligible for: 11.0 (60 minutes), 13.0 (50 minutes)
Basic or fundamental subject matter is covered. Courses are geared to general knowledge or can be taken as a refresher.
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.
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.
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.
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.
Contractors' Purchasing Systems Review
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(888) 494-3696