Raise Confirmed! DoD Finalizes Doubling of CPSR Threshold

Effective December 31, 2019, the DoD issued a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to establish a DoD contractor purchasing system review (CPSR) threshold of $50M at DFARS 244.302, doubling the existing $25M threshold at FAR 44.302(a). The final rule adopts the proposed rule (discussed here) without any substantive changes. In response to a comment, the final rule clarifies that contractors whose relevant sales have not reached the new threshold may opt to allow their approval to expire rather than incur the costs to maintain a system that meets the criteria for an approved system; in that case, the Government and contractor would continue with consent packages. But, if an approved purchasing system is necessary to support a particular program, the contractor can work with the contracting officer to obtain a CPSR based on risk or pressing need. The final rule also notes that it is a simple increase in the threshold, and does not impact any existing provisions or clauses.