44.306
Disclosure of approval status
Contractors may request the approval status of a proposed subcontractor’s purchasing system, but must independently monitor for any future changes as the government will not provide ongoing updates.
Overview
FAR 44.306 addresses how and when a contractor may be informed about the approval status of a proposed subcontractor’s purchasing system. If a contractor requests information, the Administrative Contracting Officer (ACO) may disclose whether the subcontractor’s purchasing system has been approved or disapproved. However, the ACO must also caution the contractor that the government will not provide ongoing updates about any future changes in the approval status. If the purchasing system has not been reviewed, the contractor will be informed of this as well.
Key Rules
- Disclosure Upon Request
- The ACO may inform contractors about the approval or disapproval of a proposed subcontractor’s purchasing system if asked.
- No Ongoing Updates
- Contractors are cautioned that the government will not notify them of subsequent changes in the approval status.
- Unreviewed Systems
- If the subcontractor’s purchasing system has not been reviewed, the contractor must be told this.
Responsibilities
- Contracting Officers: Respond to contractor requests regarding approval status and provide appropriate cautions.
- Contractors: Request information as needed and understand that approval status may change without notification.
- Agencies: Ensure ACOs follow disclosure and caution requirements.
Practical Implications
- This section ensures transparency for contractors seeking to verify the status of a subcontractor’s purchasing system, but also clarifies that the government does not assume responsibility for ongoing status updates. Contractors must proactively monitor subcontractor status and not rely on the government for future notifications. Failure to do so could result in compliance issues if a subcontractor’s system status changes after initial approval.