Contractor Purchasing System Review, an Alternative Perspective

Transcription

1

2 Contractor Purchasing System Review, an Alternative Perspective Breakout Session # D01 Jack Hott, CPCM, CFCM, Fellow Michael Thacker, Senior Contract Specialist, RSI Date: March 18, 2016 Time: 9:00 am 10:15am

3 Overview Historical Perspective FAR 44.3 Three Fundamentals of System Audits Existence Adequacy Compliance An Alternative Perspective - Business Systems Clauses Examining the Contractor Purchasing System Administration 24 Criteria 2

4 Historical Perspective FAR (CPSR objective) DCAS vs. Plant Cognizance Check the Box audit methodology Appendix B (Policy & Procedure checklist, 55 items) 3

5 Three Fundamentals of System Audits System Audit 101 Existence Written policies, procedures, practices Adequacy Written policies, procedures, practices address FAR, DFARS, and contract requirements Compliance Clear evidence that requirements are being met 4

6 , CONTRACTOR BUSINESS SYSTEMS , CONTRACTOR PURCHASING SYSTEM ADMINISTRATION , ACCOUNTING SYSTEM ADMINISTRATION , EARNED VALUE MANAGEMENT SYSTEM , COST ESTIMATING SYSTEM REQUIREMENTS , MATERIAL MANAGEMENT AND ACCOUNTING SYSTEM , CONTRACTOR PROPERTY MANAGEMENT SYSTEM ADMINISTRATION 5

7 DOE H CONTRACTOR BUSINESS SYSTEMS DOE H 2023 COST ESTIMATING SYSTEM REQUIREMENTS DOE H EARNED VALUE MANAGEMENT SYSTEM DOE H 2025 ACCOUNTING SYSTEM ADMINISTRATION DOE H 2026 CONTRACTOR PURCHASING SYSTEM ADMINISTRATION DOE H 2027 CONTRACTOR PROPERTY MANAGEMENT SYSTEM 6

8 Criteria Examples (DOD vs. DOE) (19) Establish and maintain 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 , Contractor Counterfeit Electronic Part Detection and Avoidance System, if applicable; (19) Establish and maintain policies and procedures to ensure purchase orders and subcontracts contain mandatory and applicable flowdown clauses, as required by the 48 CFR chapter 1, including terms and conditions required by the prime contract and any clauses required to carry out the requirements of the prime contract; 7

9 Contractor Purchasing System Administration Clause 24 criteria* 7 focus on documented procedures 7 focus on flow down requirements 7 focus on aspects of cost/price analysis and price reasonableness 16 focus on procurement memo and file documentation 3 focus on management oversight 2 focus on contract type selection * Criteria include multiple and redundant issues 8

10 Criteria Examples (redundant) (5) Establish and maintain adequate documentation to provide a complete and accurate history of purchase transactions to support vendors selected and prices paid; (8) Evaluate price, quality, delivery, technical capabilities, and financial capabilities of competing vendors to ensure fair and reasonable prices (10) Perform 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; 9

11 Criteria Examples (compound) (4) Ensure all purchase orders are based on authorized requisitions and include a complete and accurate history of purchase transactions to support vendor selected, price paid, and document the subcontract/purchase order files which are subject to Government review; Purchase requisition process Purchase history Source selection Procurement file organization and content 10

12 (4) Ensure All purchase orders are based on authorized requisitions and include a complete and accurate history of purchase transactions to support vendor selected, price paid, and document the subcontract/purchase order files which are subject to Government review; Purchase requisition process System Existence? System Adequacy? Compliance? 11

13 (4) Ensure All purchase orders are based on authorized requisitions and include a complete and accurate history of purchase transactions to support vendor selected, price paid, and document the subcontract/purchase order files which are subject to Government review; Purchase history System Existence? System Adequacy? Compliance? 12

14 (4) Ensure All purchase orders are based on authorized requisitions and include a complete and accurate history of purchase transactions to support vendor selected, price paid, and document the subcontract/purchase order files which are subject to Government review; Source selection System Existence? System Adequacy? Compliance? 13

15 (4) Ensure All purchase orders are based on authorized requisitions and include a complete and accurate history of purchase transactions to support vendor selected, price paid, and document the subcontract/purchase order files which are subject to Government review; Procurement file organization and content System Existence? System Adequacy? Compliance? 14

16 What is the purpose of CPSR? Evaluate efficiency and effectiveness of the expense of Government funds and furthering Government policies Establish purpose and responsibility for Acquisition Professional within an organization CPSR and The power of do 15