Overview
FAR 44.304 establishes the requirement for Administrative Contracting Officers (ACOs) to conduct ongoing oversight of a contractor's purchasing system to ensure continued efficiency and compliance between formal reviews.
Key Rules
- ACO Responsibility: The ACO must maintain a "sufficient" level of surveillance to verify the contractor is effectively managing its purchasing program.
- Structured Planning: Surveillance must follow a formal plan developed by the ACO with input from specialists (e.g., auditors, technical experts, and pricing specialists).
- Comprehensive Scope: The plan must cover all phases of the contract lifecycle—preaward, postaward, performance, and completion—as well as operations impacting subcontracting.
- Corrective Action Tracking: The surveillance plan must specifically evaluate the effectiveness of any corrective actions the contractor implemented following previous government recommendations.
- Efficiency and Coordination: The ACO is directed to avoid duplicating reviews that are already covered by Contractor Purchasing System Reviews (CPSR) or other monitoring activities.
Practical Implications
- Continuous Compliance: Contractors with approved purchasing systems remain under constant scrutiny; they must maintain their systems in real-time rather than just preparing for periodic formal audits.
- Interdisciplinary Oversight: Contractors should expect to interact with a variety of government specialists (DCAA, DCMA, etc.) as the ACO leverages different technical expertise to execute the surveillance plan.