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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.

May 6-7, 2021
Hyatt Regency La Jolla at Aventine
La Jolla, CA
Travel Info
Standard: $1,375.00
Premium: $1,770.00
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
  • Mike Carter
    Senior Manager
    Michael is a Senior Manager at 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...
  • Stephen "Chase" Kunk
    Vice President, Contracts & Procurement, Capital Edge Consulting
    Stephen “Chase” Kunk is Capital Edge Consulting, Inc.’s Vice President, Contracts and Procurement and CPSR Consulting Practice lead Chase specializes in U.S. Government contract and subcontract negotiations, administration, management and purchasing system compliance. His expertise...
  • John Van Meter
    Managing Director, Capital Edge Consulting
    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...
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.
CPE: Continuing Professional Education
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.
CPE Hours
This program is eligible for: 13.0 (CPE) hours of credit
Program Level: Intermediate
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)
Hyatt Regency La Jolla at Aventine
3777 La Jolla Village Drive
La Jolla, CA, 92122
Hotel & Room Block Info

We have a room block secured for the La Jolla weeklong event. For guest room reservations, call 800.937.8461 and reference the Federal Publications room block. Group rate is $239 + taxes/night. Click here to make your reservation. You must make your reservation by April 1, 2021. Rooms are subject to availability.

Government Per Diem

A limited number of Government per diem rate rooms have been set aside. Click here DIEM to make your reservation. You must make your reservation by April 1, 2021. Rooms are subject to availability.

General Information

Food & Beverage

During La Jolla Government Contracts Week, we will be serving continental breakfast, lunch and an afternoon snack each day.

  • 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.