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Glossary

What Is a CPSR? Contractor Purchasing System Review
What is a CPSR? And what triggers one

A Contractor Purchasing System Review is the government's examination of how a contractor buys under government contracts. It looks at your policies, your files and the decisions inside them, and its outcome decides how much purchasing autonomy you keep.

Run by DCMA for defense workReviewed against FAR Part 44
QUICK ANSWERFAR PART 44
CPSR
Contractor Purchasing System Review · decides how much purchasing autonomy you keep
DEFENSE OR CIVILIAN · TAP TO COMPARE
Who reviewsDCMAAdministering agency
Assessment threshold$50M$25M
Primary clauseDFARS 252.244-7001FAR 52.244-2
Criteria24 system criteriaFAR 44.202-2 factors
Expected government sales in the next 12 months. Crossing it triggers a risk assessment, not the review itself.Expected government sales in the next 12 months. Crossing it triggers a risk assessment, not the review itself.
OUTCOME FOR YOUR PURCHASING SYSTEM
GrantedWithheldWithdrawnWithheld = consent per subcontract
DIRECT ANSWERChecked August 2026

A Contractor Purchasing System Review, or CPSR, is a government review of how a contractor purchases under its government contracts. For defense work it is carried out by DCMA. Its purpose is to decide whether the contracting officer can approve your purchasing system, and an approved system means you keep the authority to place subcontracts without seeking consent each time.

The short version

Who runs it, and why it matters to you

The review is about your system rather than any single purchase. What it produces is a decision about how much purchasing autonomy you keep.

Glossary • Walkthrough

Who runs it, and why it matters to you

The review is about your system rather than any single purchase. What it produces is a decision about how much purchasing autonomy you keep.

  • DCMA runs it for defense work; civilian agencies under FAR Part 44
  • Crossing the sales figure triggers a risk assessment, not the review
  • Approval decides whether you place subcontracts without consent
PURCHASING SYSTEM REVIEW
What a CPSR decides
FAR PART 44
WHO RUNS IT
DCMA for defense work
Civilian agencies run equivalent reviews under FAR Part 44
WHAT IS REVIEWED
Policies and a sample of real purchase files
Files are tested against your own policy
WHAT TRIGGERS ONE
$25M expected government sales
FAR 44.302 · $50M for defense under DFARS 244.302
OUTCOME
Approval granted, withheld or withdrawn
Decided by the administrative contracting officer
IF WITHHELD
Advance notification and consent
Before placing subcontracts, which slows buying
QuestionAnswer
Who runs itFor Department of Defense work, the Defense Contract Management Agency. Civilian agencies run their own equivalent reviews under FAR Part 44.
What is reviewedYour purchasing policies and procedures, and a sample of actual purchase files tested against them.
What triggers oneFAR 44.302 directs the contracting officer to assess the need when your government sales are expected to exceed $25 million in the next 12 months. DFARS 244.302 sets that figure at $50 million for defense contractors. Certain competitively awarded fixed price work and commercial items under FAR Part 12 are excluded from the calculation.
Is it automatic at the thresholdNo. Crossing the figure triggers a risk assessment, not the review itself. Past performance and the volume, value and complexity of your subcontracts all feed the decision.
What is the outcomeThe administrative contracting officer grants, withholds or withdraws approval of your purchasing system.
What if approval is withheldYou generally have to notify the contracting officer in advance and obtain consent before placing subcontracts, which slows down buying considerably.
What the reviewers actually look at

Policies on one side, purchase files on the other

The review has two halves, and contractors who fail usually do so on the second one rather than the first.

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Glossary • Walkthrough

Policies on one side, purchase files on the other

The review has two halves, and contractors who fail usually do so on the second one rather than the first.

  • Policies are checked for coverage and current regulation
  • A sample of files is tested against your own policy
  • Consistency across buyers is read as evidence of a system
REVIEW SAMPLE
Where it goes wrong, and the fix
COMMON FINDINGTHE FIX
01Your policies
Outdated, or not followed Review and align
02Your purchase files
Analysis missing, reasoning absent Capture at the decision
03Consistency
Uneven across buyers Structure, not effort
04Flow downs
Sent outside the file Attach to the award
MOST FINDINGS ARISE IN THE FILES, NOT THE POLICIES
ProcureAudit What is examined
The challenge

What is examined

Whether you have written purchasing policies, whether they cover the topics the review addresses, and whether they cite regulations that are still current.

WrittenRequired
CurrentChecked
CoverageAgainst review topics
ProcureAudit Where it goes wrong
With ProcureAudit

Where it goes wrong

Policies that were written once and never revised, that cite superseded regulation, or that describe a process the team has quietly stopped following.

Common findingOutdated
Also commonNot followed
FixReview and align
ProcureAudit What is examined
The challenge

What is examined

A sample of actual purchase orders and subcontracts, tested to see whether each one contains the analysis, justification and approvals your policy requires.

MethodSampling
Tested againstYour own policy
DepthFile by file
ProcureAudit Where it goes wrong
With ProcureAudit

Where it goes wrong

Price or cost analysis missing, sole source justifications that assert rather than demonstrate, flow down clauses incomplete, and reasoning that was never written down at the time.

Common findingAnalysis missing
Also commonReasoning absent
FixCapture at the decision
ProcureAudit What is examined
The challenge

What is examined

Whether the files behave the same way across buyers and across time, or whether documentation quality depends on who placed the order and how busy that quarter was.

Looking forConsistency
AcrossBuyers and periods
SignalVariation
ProcureAudit Where it goes wrong
With ProcureAudit

Where it goes wrong

One buyer documents thoroughly and another does not, or standards visibly drop in the busiest months, which suggests the system depends on individuals rather than process.

Common findingUneven
CauseManual discipline
FixStructure, not effort
ProcureAudit What is examined
The challenge

What is examined

Whether required clauses were passed to subcontractors, and whether the file shows what was flowed down on each award.

CheckedPer subcontract
EvidenceIn the file
Depends onContract type and value
ProcureAudit Where it goes wrong
With ProcureAudit

Where it goes wrong

Clauses sent by separate email with nothing in the purchase file recording what the subcontractor accepted or when.

Common findingNot evidenced
CauseSent outside the file
FixAttach to the award
Defense and civilian reviews are not identical

Different criteria, similar purpose

Defense contractorsCivilian agency contractors
Primary clauseDFARS 252.244-7001, which sets out 24 system criteriaFAR 52.244-2, with the factors at FAR 44.202-2
Assessment threshold$50 million expected government sales, per DFARS 244.302$25 million expected government sales, per FAR 44.302
GuidanceThe DCMA CPSR GuidebookAgency guidance, with the special attention areas at FAR 44.303
Who reviewsThe Defense Contract Management AgencyThe administering agency
FAQ

Common questions about purchasing system reviews

What does CPSR stand for?
Contractor Purchasing System Review. It is the government's review of how a contractor buys under its government contracts, covering both the written policies and a sample of real purchase files.
What is the CPSR threshold?
FAR 44.302 directs the contracting officer to assess the need for a review when government sales are expected to exceed $25 million over the next 12 months. DFARS 244.302 sets that at $50 million for defense contractors. Certain competitively awarded fixed price work and FAR Part 12 commercial items are excluded from the calculation.
Is a review automatic once I cross the threshold?
No. Crossing the figure triggers a risk assessment rather than the review itself. The contracting officer also weighs past performance and the volume, dollar value and complexity of your subcontracts.
Who carries out the review?
For Department of Defense work, the Defense Contract Management Agency. Civilian agencies conduct their own reviews under FAR Part 44 using the factors at FAR 44.202-2.
What happens if my purchasing system is not approved?
You generally have to give the contracting officer advance notification and obtain consent before placing subcontracts. That does not stop you working, but it adds a step to every award and slows purchasing down.
What are the most common findings?
Two dominate. Policies that are outdated or describe a process the team no longer follows, and purchase files missing the price or cost analysis, sole source justification or written reasoning that the policy requires.
How far ahead should we prepare?
Preparation is mostly about how files were built at the time, so the useful work happens continuously rather than in the weeks before a review. Reasoning that was never written down cannot be recovered later, only reconstructed.
Does software make us CPSR ready?
No software can make that determination for you, and we would be wary of any that claims to. What a purchasing workspace can do is make consistent documentation the normal path, so the files hold the analysis and reasoning when somebody examines them.
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See what a purchase file can hold

Bring an award you would rather not have sampled. We will show what the record would contain if the reasoning had been captured at the decision.

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