Overview
This section outlines the operational framework for the Defense Priorities and Allocations System (DPAS), establishing the hierarchy of priority ratings and defining the responsibilities of agencies and contracting officers in executing, managing, and enforcing rated orders.
Key Rules
- Priority Hierarchy: There are two levels of rated orders: "DX" (highest priority) and "DO" (critical to national defense). DX orders take precedence over DO orders, and both take precedence over unrated orders.
- Mandatory Compliance: Rated orders must be placed in accordance with 15 CFR 700, and agency heads are responsible for ensuring contracting activities comply with these regulations.
- Flowdown Requirement: The DPAS regulation requires the extension of priority ratings (flowdown) from prime contractors to subcontractors and suppliers at all tiers.
- Special Priorities Assistance (SPA): If contracting officers or contractors experience difficulties (e.g., locating suppliers or ensuring timely delivery), they must promptly seek assistance through agency-specific procedures.
- Enforcement and Reporting: The Department of Commerce has the authority to take official actions (such as administrative subpoenas or directives) to enforce DPAS, and contracting officers are mandated to report any violations to the Department of Commerce.
Practical Implications
- Production Prioritization: Contractors must prioritize the performance of rated orders over unrated or commercial orders, which may require rescheduling other work to meet delivery dates.
- Supply Chain Management: Contracting officers and prime contractors must ensure that every subcontract for items needed to fulfill a rated order also carries the priority rating to prevent bottlenecks.
- Problem Resolution: The SPA process provides a formal mechanism for the government to intervene in the marketplace to resolve supply chain conflicts or resource shortages.