CFCM Subcontract Management 5 — Questions and Answers
Question 1: Which federal regulation specifically addresses counterfeit electronic parts and requires detection and avoidance systems in defense contractor supply chains?
- FAR 52.246-26
- DFARS 252.246-7007 (Correct answer)
- FAR 52.244-6
- DFARS 252.225-7009
Correct answer: DFARS 252.246-7007
DFARS 252.246-7007, Contractor Counterfeit Electronic Part Detection and Avoidance System, requires defense contractors to maintain systems to detect, report, and avoid counterfeit parts.
Question 2: Under FAR Part 9, what is the contracting officer's obligation before awarding a subcontract consent on a cost-reimbursement prime?
- Verify the proposed subcontractor is not suspended or debarred in SAM.gov (Correct answer)
- Conduct a pre-award survey of the subcontractor's facilities
- Obtain SBA size certification for all proposed subcontractors
- Issue a separate solicitation for the subcontracted work
Correct answer: Verify the proposed subcontractor is not suspended or debarred in SAM.gov
Before consenting to a subcontract, the CO must verify the proposed subcontractor is not listed as suspended or debarred in SAM.gov per FAR 9.405.
Question 3: A subcontractor performing classified work under a prime contract must have which document before beginning classified work?
- A Contractor Team Arrangement (CTA) approved by the CO
- A Facility Security Clearance (FCL) granted by the Defense Counterintelligence and Security Agency
- An approved DD Form 254, Contract Security Classification Specification
- Both B and C (Correct answer)
Correct answer: Both B and C
Subcontractors performing classified work need both an FCL from DCSA and a DD Form 254 that flows down the security requirements from the prime contract.
Question 4: Under the Subcontracting Assistance Program (SAP), when a prime contractor fails to make good faith efforts to meet small business subcontracting goals, what is the potential consequence?
- Automatic contract termination for convenience
- Liquidated damages calculated based on the unmet goal amount (Correct answer)
- Debarment from all federal contracting for 3 years
- Reduction of award fee by a fixed percentage
Correct answer: Liquidated damages calculated based on the unmet goal amount
Under FAR 19.705-7, a prime contractor that fails to make good faith efforts to comply with its subcontracting plan may be assessed liquidated damages equal to the amount by which it failed to achieve each goal.
Question 5: What is the 'ostensible subcontractor rule' in SBA size standard determinations?
- A rule requiring subcontractors to be disclosed in all small business set-aside bids
- A rule that affiliates a prime with its subcontractor when the sub performs primary work or the prime is unduly reliant on the sub (Correct answer)
- A rule prohibiting small businesses from subcontracting more than 50% of a contract
- A rule requiring the government to verify subcontractor size at award
Correct answer: A rule that affiliates a prime with its subcontractor when the sub performs primary work or the prime is unduly reliant on the sub
The ostensible subcontractor rule treats a prime and its subcontractor as affiliates when the subcontractor performs the primary work or when the prime is unduly reliant on the subcontractor for key personnel or expertise.
Question 6: Under FAR 52.245-1, which party is responsible for maintaining property control records for government-furnished property (GFP) provided to a subcontractor?
- The subcontractor independently reports directly to the government
- The prime contractor, who must flow down property requirements and maintain stewardship (Correct answer)
- The cognizant property administrator assigned to the subcontractor
- The government retains all records; no contractor obligation exists
Correct answer: The prime contractor, who must flow down property requirements and maintain stewardship
The prime contractor remains accountable for GFP at all subcontract tiers and must flow down property management requirements, maintaining overall stewardship under FAR 52.245-1.
Question 7: Which of the following best describes the purpose of a 'back-to-back' contract structure in federal subcontracting?
- A method where the prime creates subcontract terms that mirror the prime contract obligations applicable to the subcontractor's scope (Correct answer)
- A technique where two subcontractors share equal responsibility for the same deliverable
- A financing arrangement allowing subcontractors to invoice twice per month
- A contract structure where a subcontractor directly assumes the prime's entire obligation
Correct answer: A method where the prime creates subcontract terms that mirror the prime contract obligations applicable to the subcontractor's scope
A back-to-back contract mirrors the relevant prime contract terms downstream to the subcontract, ensuring the subcontractor is bound by the same obligations that flow from the government to the prime.
CFCM Subcontract Management 5
Which federal regulation specifically addresses counterfeit electronic parts and requires detection and avoidance systems in defense contractor supply chains?