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Federal Award Entry Navigator Services

With the recent increase in Federal spending from the bipartisan infrastructure bill signed into law on November 15, 2021, commercial companies are increasingly interested in pursuing federal funding to sponsor their research, fund their underlying missions,  and diversify their market base. A major challenge for those players new to the federal space is complying with Title 2 of the Code of Federal Regulations (2 CFR). Capital Edge can either deliver fully compliant outsourced operations for you or guide you through establishing your own compliant operations with training, processes, and controls development and audit readiness.  We work to insulate your commercial business from government regulatory requirements while maximizing cost recovery, minimizing risk, and providing controls and visibility for executive management over federal awards.

Pathway 1: Fully Outsourced Approach

Capital Edge’s Federal Award Entry Navigator (“Navigator”) team was assembled to provide full back-office services for new federal entities, establishing the compliant accounting, procurement, estimating, materials management, and contracts capabilities.  We will allow your new federal entity to remain focused on its primary mission while we take care of compliant administrative operations. We establish an operational cadence and control structure designed specifically for your business that allows you to maintain total control over your banking, payroll, and taxes with full visibility into your accounting and financials while we provide the systems, people, and processes to run the administrative functions.

Pathway 2: Guided Development of Compliant Processes and Controls

Understanding the regulations and requirements is difficult enough, but to meet the compliance requirements, a company must develop a framework of processes and controls beyond GAAP. Balancing the requirements of the regulations while also enabling smooth and timely operations can be very delicate. While some companies pursue regulatory conservatism, paralyzing operations, others take a minimalistic approach, operating with modest adoption of compliant practices and controls and risking audit findings and loss of funding.

The team has a history of assisting long-time federal awardees with training, policies, procedures, best practices, systems implementations, and audit preparation from highly regulated industries. Navigator leaders hold executive operational experience and extensive process development, process improvement, and systems experience in the government contracting space. Over the past several years, the Navigator team has leveraged experience and knowledge to guide clients through their government award recipient journey to successfully bid, win, and execute federal awards.

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Navigator Pathway 1: Fully Outsourced Approach

The Navigator pathway begins with a series of workshops to understand goals, objectives, and the current state of the nascent federal practice as well as the mission the federally funded work supports. With this information, the Navigator team will help you complete the registration on the System for Award Management (SAM.gov). While that SAM registration is underway, Capital Edge will work with you to establish the details of our working relationship that allow you to maintain total control of your money and your business while we provide the execution support. Capital Edge will provide operations and award administration including procurement, project finance, accounting, contract administration, accounts payable, and accounts receivable. These functions will be performed by employees familiar with the requirements of federal awards and operate according to Policies and Procedures developed around your mission objectives and compliance requirements.

Federal Award Pathway

Navigator Pathway 2: Guided Development Of Compliant Processes & Controls

The Navigator pathway begins with a series of workshops to understand goals, objectives, and the current state of the nascent federal practice as well as the mission the federally funded work supports. With this information, the Navigator team will help you complete the registration on the System for Award Management (SAM.gov). During the workshops, the Navigator team will provide information and education on critical terminology and concepts foundational to federal compliance. Once those basics are covered, our team collaborates with your team, leveraging templates and best practices, to create a service framework tailored to your business needs. This framework is codified in the procedures and work instructions and then operationalized through the purchase and implementation or configuration of your business system setup. The Navigator team will be by your side in preparation for and leading audits as well as providing regulatory, contractual, or corporate reporting.

Federal Award Entry Pathway

Workshops

As the name suggests, the Navigator team is skilled in seamlessly directing the team along the path to federal compliance escaping the common pitfalls of missed or misunderstood requirements, overshooting or undershooting the intended purpose, or inefficient operations. The first and most important step in this process is conducting workshops. During these sessions, the Navigator team will facilitate a discussion to understand the corporate goals and objectives for federal awards, steps taken to date on proposing, bidding, and winning work, and the current state of policies, procedures, and systems to assess against the required compliance framework. It is critically important for the Navigator team to understand the federal mission and how your research, products, and services support that mission. This information enables the team to tailor processes best suited to your objectives and current posture. During the Workshops, the Navigator team will share educational materials on basic terminology and concepts for federal compliance to create a shared language for the combined team. Wrapping up the workshops, the Navigator team will recommend an operational roles & responsibilities to support back-office functions for federal award administration and plan for future growth.

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Business Systems

To operationalize the compliance framework, the required project costing, workflows, and controls need to be housed in your enterprise business systems for an audit trail of transactions and proper documentation. Capital Edge’s Federal Award Entry Navigator team is experienced in selecting, designing, implementing, and maintaining ERP and other business systems. Our team works across a large variety of ERP systems enabling us to help you select the system that is best for your business’ needs and requirements. We provide expert leadership throughout the entire ERP lifecycle from planning through go-live and beyond to upgrades, health checks, business system setup, and evolving existing systems.

Temporary Operational Services

For those new to the federal space, the first award is a major milestone to be celebrated. Awards may start slowly and grow steadily, making it challenging to justify hiring employees with federal experience to perform key roles in procurement, accounting, and finance, which are critical to compliant award administration. Capital Edge’s Operational Services provide the staff to execute award administration, reducing the burden of hiring or bifurcating commercial processes for existing support functions. Given these differences, the Navigator team will work with you to architect a service offering that augments your existing team in accounting, purchasing, contracts, billing, timekeeping, expense management, or pricing as much or as little as needed. 

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Why Choose Us

As federal funding increases for modernizing US infrastructure, more commercial and start-up companies are pursuing federal awards to partner in our nation’s development as well as to supplement internal research and development investment. Capital Edge’s Federal Award Entry Navigator service provides solutions to the hurdles of accepting federal awards by leading the journey to establish compliant business systems that will withstand an audit while optimizing operational efficiency. Navigator removes an additional barrier in business operations by providing back-office services for federal award administration including procurement, project finance, accounting, and contract administration. This comprehensive service de-risks and simplifies regulatory compliance enabling businesses to focus on their core mission, delivering products and services to advance our country’s foundation for future generations.

Frequently Asked Questions

Here are the latest questions being asked about CPSR

Does a CPSR include purchasing and subcontracting?

Yes. Except for certain transactions excluded under FAR 44, your purchasing and subcontracting activities are within CPSR scope. DFARS 252.244-7001 defines the purchasing system to include the “…the system or systems for purchasing and subcontracting…”

What are Common Federal Purchasing System Deficiencies?

According to DCMA CPSR Reports issued in GFY2019, DCMA identified that the “most common material deficiencies” related to:

  • Debarment
  • Payments to Influence
  • Cost Analysis / Price Analysis
  • DPAS
  • FFATA
  • Sole Source Justification
  • Policy & Procedure Manual
  • Commercial Item Determinations (CID)
  • Truthful Cost in Pricing Data (formerly known as Truth-in-Negotiations Act or TINA)
  • Negotiations
Who performs the "CPSR Audit"?
A CPSR is not an “audit” but a “review.” Within the Department of Defense (DoD), the Defense Contract Management Agency (DCMA), specifically the DCMA CPSR Group, is responsible for reviewing the contractors’ purchasing systems. The DCMA CPSR Group is comprised of “analysts;” not “auditors.” In some cases, DCMA also reviews the purchasing system of contractors’ that do not hold DoD contracts.

What are the Impacts of a Purchasing System Disapproval?

A DCMA purchasing system disapproval can cause many issues for a contractor, including:

  • Increased oversight of contractor’s business (e.g. audits and reviews of other business systems, etc.) and delay in the government acquisition process;
  • Increased application of government consent to subcontract requirements;
  • Potential withhold of payments;
  • Competitive disadvantage in responding to Government requirements; and
  • Disclosure via Contractor Business Analysis Repository.
What is the Current CPSR Requirement Threshold

A CPSR is performed on a discretionary basis, if deemed necessary by the Administrative Contracting Officer (ACO).  The ACO’s decision to determine the need can be, in part, influenced by the contractor’s anticipated FAR-44 qualifying sales volume and results of the contractor risk assessment.

  • FAR 44.302: Greater than $25M in the next 12 months. 
  • DFARS 244.302: Greater than $50M in the next 12 months. 

Caution: The CPSR dollar threshold is discretionary and may be lowered or raised. (FAR 44.303).

 

Where can the CPSR requirements be found?
The specific subject matter areas evaluated in a DCMA CPSR can be found in the DCMA CPSR Guidebook under the “Major Purchasing Areas” subsection as well as in the associated appendices to the Guidebook.
What is the CPSR Guidebook?

The Contractor Purchasing System Review (CPSR) Guidebook is published by the DCMA. The purpose of the DCMA Guidebook is to provide “…guidance and procedures to Government personnel for evaluating contractor purchasing systems and preparing the CPSR reports.”

Click-to-see the 2021 Revised CPSR Guidebook

 

What is CPSR certification?

The phrase “CPSR certification” is a misnomer. Rather, a CPSR is a review conducted by the government that results in a report which provides the basis, at least in part, for the cognizant federal agency official to make a decision – e.g. that the system is acceptable and approved. FAR 44.305 is very clear as to who has purchasing system approval authority – “The cognizant ACO is responsible for granting, withholding, or withdrawing approval of a contractor’s purchasing system.”

 

What Does CPSR Stand for?
“CPSR” stands for Contractor Purchasing System Review.

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About Capital Edge Consulting

Capital Edge government contract consultants support Government Contractors and Federal Grant Recipients. Our consultants specialize in the regulatory compliance matters you need.

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