CPSR Frequently Asked Questions

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UpgradeX recommends preparing for the CPSR 14+ months in advance of the planned review date. DCMA will select PO samples from a 12-month window of time that ends approximately 1-2 months in advance of the review. For example, If the review is scheduled in May 2026, DCMA may select POs placed from April 1, 2025 – March 31, 2026. 

Companies should give themselves enough time to ensure their policies are adequate to the Purchasing System requirements, be sure that staff is trained on all of the updates, and that the practices align with the updated policies so that the documentation that will be pulled in the sample window will show as compliant. 

Ideally, if companies can do so, they should start preparing more than 14 months in advance. Give yourself as much time as possible! 

To best prepare for a CPSR, companies should give themselves enough time to adequately review and update policies and practices, provide staff training, and to start an initial review of the potential PO Universe. 

UpgradeX has a step-by-step checklist with recommended timelines that start 14+ months in advance of the review. 

Complete the Contact UpgradeX form, and someone from The Upgrade Force will contact you to schedule time to walk through the checklist with you. 

The general requirements for a Contractor Purchasing System are found in DFARS 252.244-7001, Contractor Purchasing System Administration, however, contractors will not find detailed guidance within this clause. DCMA has created a Contractor Purchasing System Review (CPSR) Guidebook, which contractors can use to better understand the requirements as well as prepare for reviews. The guidebook does not replace or supersede the regulations. 

Together, the guidebook and the DFARS 252.244-7001 clause are helpful, but will not provide the contractor with explicit instructions on how to best meet the requirements. They will not tell you everything a contractor needs to know to be compliant, such as, for example, how to write policies and forms and other command media, how to create a file organization process or an internal review/audit process, or what should be included in a source selection or price analysis. 

Not only will the procurement practices and documentation be reviewed during a CPSR, but so will the procurement policies (as well as any cross-functional policies associated with the purchasing processes, such as in Quality, Finance, or Cybersecurity). Policies need to give staff guidance on all regulations that are required to be supported by a Purchasing System worthy of USG acceptance, when the regulations apply or when there are exceptions, how to meet the requirements, and how to document compliance. The practice needs to align with the policies and other command media. Any gaps can lead to deficiencies that can be noted and documented in a CPSR. 

Contractors that are not very familiar with the Purchasing System requirements or CPSR processes are encouraged to seek additional guidance and support. Contact UpgradeX to see how we can assist you.

The actual review portion of the CPSR typically takes place over a 2-week period. Prior to that, however, DCMA will notify the contractor/subcontractor of the CPSR approximately 2-3 months in advance, and will start requesting various pieces of information, usually in a DCMA required format. After the review, if there are any deficiencies, DCMA will issue a Corrective Action Request (CAR) and require the contractor to provide a Corrective Action Plan (CAP) to address all deficiencies listed in the CAR. The CAP must be submitted within 30 calendar days of receipt of the CAR and shall not only detail the plan for the corrections, but DCMA will want to see verifiable evidence that the plan is being or has been implemented. 

All in all, without accounting for any preparation time by the contractor, a typical CPSR will take place over a 3–5-month period, with the 2-week review and the CAP development and response phases of the review demanding the most dedicated time.

UpgradeX has created a step-by-step checklist that includes all of the typical steps and associated timeline relative to the CPSR. Complete the Contact UpgradeX form, and someone from The Upgrade Force will contact you to schedule time to walk through the checklist with you. 

See also the previous question, “What is the general timeline or schedule of a CPSR?”. 

CPSRs are not to be taken lightly. They can be very time intensive over several months. If a company is not prepared, the level of involvement and amount of time required can significantly increase. 

Responding to the initial CPSR RFIs can require only a few hours of work, often from multiple departments in an organization. However, proper due diligence should be performed to ensure accuracy and completeness of the information, as the responses can impact the result of the CPSR. Contractors that are not very familiar with the Purchasing System requirements or CPSR processes are encouraged to seek additional guidance and support. 

The 2-week review will be significantly more labor intensive, as DCMA will often ask a lot of questions during the PO Sample review, which may include requests for additional support documentation. Responses to any questions must be provided within a 24-hour period. 

The Corrective Action Plan (CAP) development and implementation phase will require significant time commitment from certain stakeholders in the Procurement department. Seeking an experienced company, such as UpgradeX, to assist in this phase is recommended. 

UpgradeX has developed a CPSR review and CAP process that recommends a certain level of engagement by specific individuals. Complete the Contact UpgradeX form, and someone from The Upgrade Force will contact you to schedule a discussion. 

Over the past 2-dozen CPSRs that the Managing Director of UpgradeX has been involved in, of the 30 CPSR elements reviewed during a CPSR, the most common deficiencies are as follows:

• Debarment
• Anti-Lobbying (Payments to Influence)
• DPAS
• Documentation
• FFATA (Reporting subawards and executive compensation)
• Price/Cost Analysis
• Source Selection 
• Commercial Item Determinations
• Negotiations

Often, the leading cause of some of the deficiencies is not having adequate policies and procedures. DCMA may not state that as a specific deficiency, as they do not want to throw another deficiency into the mix when it may be covered under the defining requirement, but it is not uncommon to also see Policies and Procedure Manual as a deficiency.