Surveillance
ACO-led surveillance ensures contractors maintain effective purchasing systems and that corrective actions are properly implemented, while avoiding redundant government reviews.
Overview
FAR 44.304 outlines the requirements for the Administrative Contracting Officer (ACO) to maintain ongoing surveillance of a contractor’s purchasing system. The purpose is to ensure that contractors are effectively managing their purchasing programs and complying with government standards. Surveillance must be systematic and based on a plan developed by the ACO, with input from relevant specialists such as those in subcontracting, audit, pricing, and technical fields. The surveillance plan should address all phases of the contractor’s purchasing system, including preaward, postaward, performance, and contract completion. It must also include procedures for reviewing the effectiveness of corrective actions taken by the contractor in response to previous government recommendations. The regulation emphasizes avoiding redundant reviews by different government entities, such as the Contractor Purchasing System Review (CPSR) team and other surveillance monitors.
Key Rules
- ACO Surveillance Requirement
- The ACO must maintain sufficient oversight to ensure effective contractor purchasing management.
- Surveillance Plan Development
- The ACO, with specialist assistance, must develop a comprehensive surveillance plan covering all relevant phases and operations of the contractor’s purchasing system.
- Review of Corrective Actions
- The plan should include procedures to assess the effectiveness of contractor responses to prior government recommendations.
- Avoidance of Duplicative Reviews
- Surveillance activities should be coordinated to prevent redundant reviews by CPSR and other monitors.
Responsibilities
- Contracting Officers: Develop and implement a surveillance plan, coordinate with specialists, and avoid duplicative reviews.
- Contractors: Cooperate with surveillance activities and implement effective corrective actions.
- Agencies: Provide necessary specialist support and ensure oversight is efficient and non-duplicative.
Practical Implications
- Ensures continuous oversight of contractor purchasing systems to mitigate risks and ensure compliance.
- Contractors must be prepared for ongoing reviews and demonstrate effective corrective actions.
- Poor coordination can lead to redundant reviews, increasing administrative burden for both government and contractors.