CFCM Standards & Best Practices 4 — Questions and Answers
Question 1: What is the primary purpose of a Contractor Purchasing System Review (CPSR) conducted by DCMA?
- To audit incurred costs on cost-reimbursement contracts
- To assess whether the contractor's purchasing system is efficient and compliant with FAR requirements (Correct answer)
- To review contractor payroll records for prevailing wage compliance
- To evaluate the contractor's bid and proposal preparation costs
Correct answer: To assess whether the contractor's purchasing system is efficient and compliant with FAR requirements
A CPSR evaluates whether a contractor's purchasing system provides reasonable assurance that the contractor performs its subcontracting in compliance with FAR and contract requirements.
Question 2: Under FAR Part 12, which statement best describes the standard commercial terms and conditions concept for commercial item contracts?
- The government must always use its own standard clauses regardless of industry practice
- The government may tailor or omit clauses that are inconsistent with customary commercial practice (Correct answer)
- Commercial item contracts require CAS compliance
- The government must negotiate prices using cost or pricing data
Correct answer: The government may tailor or omit clauses that are inconsistent with customary commercial practice
FAR Part 12 allows the government to use contract terms and conditions consistent with customary commercial practice, and authorizes tailoring of clauses to avoid imposing requirements inconsistent with commercial standards.
Question 3: What is the best practice for documenting a sole source justification under FAR 6.303-1?
- A brief email from the requiring office is sufficient
- Justification and Approval (J&A) must be signed by the appropriate authority before award (Correct answer)
- The CO may document the justification after award if exigent circumstances existed
- A market survey is not required for sole source acquisitions under the SAT
Correct answer: Justification and Approval (J&A) must be signed by the appropriate authority before award
FAR 6.303 requires a written Justification and Approval (J&A) signed by the appropriate authority (based on dollar threshold) before the contract is awarded.
Question 4: Which performance standard is MOST appropriate when the government cannot define precise requirements but needs flexibility in how outcomes are achieved?
- Design specification with detailed SOW
- Performance work statement (PWS) with measurable outcomes (Correct answer)
- Firm-fixed-price LOE contract
- Time-and-materials contract with mandatory hours
Correct answer: Performance work statement (PWS) with measurable outcomes
A Performance Work Statement defines required outcomes and measurable standards rather than prescribing methods, giving contractors flexibility while ensuring accountability.
Question 5: Under Cost Accounting Standards (CAS), when must a contractor file a Disclosure Statement (DS-1)?
- When total CAS-covered awards exceed $2 million in a cost accounting period
- When the contractor first receives a CAS-covered contract of $50 million or more, or when total CAS-covered awards exceed $50 million (Correct answer)
- Before submitting any government bid regardless of amount
- Only for contracts with educational or nonprofit institutions
Correct answer: When the contractor first receives a CAS-covered contract of $50 million or more, or when total CAS-covered awards exceed $50 million
CAS 9903.202-1 requires a Disclosure Statement when a contractor first receives a CAS-covered contract of $50 million or more, or when total CAS-covered awards in an accounting period exceed $50 million.
Question 6: Best practices for federal contract debriefings under FAR 15.506 include which of the following?
- Disclosing the rankings and scores of all competing offerors
- Providing the rationale for award and strengths/weaknesses of the debriefed offeror's proposal (Correct answer)
- Sharing the winning contractor's pricing and technical approach
- Postponing the debriefing until after the protest deadline has passed
Correct answer: Providing the rationale for award and strengths/weaknesses of the debriefed offeror's proposal
FAR 15.506 requires that debriefings cover the evaluation of the debriefed offeror's proposal, including strengths and weaknesses, but prohibit disclosure of other offerors' trade secrets or rankings.
Question 7: Which acquisition planning best practice is required by FAR 7.102 for acquisitions exceeding the simplified acquisition threshold?
- A market research report filed with FPDS-NG
- A written acquisition plan developed by the requiring activity with CO participation (Correct answer)
- An independent government cost estimate certified by DCAA
- A small business subcontracting plan submitted to the SBA
Correct answer: A written acquisition plan developed by the requiring activity with CO participation
FAR 7.102 mandates a written acquisition plan for acquisitions above the simplified acquisition threshold, developed collaboratively by the program office and contracting office.
CFCM Standards & Best Practices 4
What is the primary purpose of a Contractor Purchasing System Review (CPSR) conducted by DCMA?