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Guide

Purchasing System Review Checklist
What a review examines, area by area

Reviews work through your written policies and then through a sample of real purchase files. This is what each half looks at, and where contractors most often come up short.

Defense reviews use 24 system criteriaFiles matter more than policies
QUICK ANSWER
24system criteria
Used in defense purchasing system reviews
Written policies, then a sample of files
Most findings arise in the files
Consistency across buyers is tested
DIRECT ANSWERChecked August 2026

A contractor purchasing system review examines both your written purchasing policies and a sample of actual purchase files tested against them. Defense reviews work from the criteria in DFARS 252.244-7001 and the DCMA guidebook; civilian reviews use the factors in FAR Part 44. Most findings arise in the files rather than the policies.

The two halves of a review

And where the weight actually falls

Teams routinely spend most of their preparation on the policy document and then fail on the files, which are what the reviewers spend most of their time in.

Guides • Walkthrough

The two halves of a review

A review tests your written policies first, then pulls a sample of purchase files to see whether practice matches them.

  • Policies are measured against the system criteria
  • A file sample tests what buyers actually did
  • Most findings come from the gap between the two
HALF 1 + HALF 2WHERE FINDINGS ARISE
HALF 1
Written policies
VS CRITERIA
HALF 2
File sample
2 FILES FLAGGED
The gap between them
A policy says one thing; a file shows another. That is where most findings come from.
FINDINGS
HalfWhat is examinedWhere contractors stand
Written policiesWhether policies exist, cover the topics the review addresses, cite current regulation and describe the process actually followedUsually present. The common weakness is drift: accurate when written, describing something else now
Purchase filesA sample of real purchase orders and subcontracts, tested for the analysis, justification, approvals and flow-down evidence your own policy requiresWhere most findings arise. A file can hold every document and still fail to explain the decision
ConsistencyWhether files behave the same way across different buyers and different periodsThe quiet test. Variation suggests the outcome depends on individuals rather than a system
Practice against policyWhether what the files show matches what the policy saysThe gap itself is what gets cited, rather than either half in isolation
The areas that produce most findings

Four that recur across reviews

These are not exotic. They are the same four, and each is preventable at the point the award is placed.

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ProcureAudit Absent from the file
The challenge

Absent from the file

The file contains quotes and an order but nothing recording why that supplier was chosen over the others, because it was obvious at the time.

PresentNo
RecoverableNot convincingly
FrequencyVery high
ProcureAudit Written at the decision
With ProcureAudit

Written at the decision

The buyer records the basis for selection as they decide, attached to the award, so the file explains itself to a reader who was not there.

PresentYes
RecoverableNot needed
FrequencyRare finding
ProcureAudit A price and a conclusion
The challenge

A price and a conclusion

The file states the price is fair and reasonable without naming the technique used or showing the comparators behind it.

Method namedNo
Working shownNo
FrequencyVery high
ProcureAudit Method and working
With ProcureAudit

Method and working

The file states whether price or cost analysis was performed, identifies the comparators, and shows enough working to follow the conclusion.

Method namedYes
Working shownYes
FrequencyRare finding
ProcureAudit Asserted
The challenge

Asserted

The justification concludes that only one supplier could meet the need without naming who else was considered or why each was ruled out.

Alternatives namedNo
Price testedOften not
FrequencyHigh
ProcureAudit Demonstrated
With ProcureAudit

Demonstrated

Alternatives are named with specific reasons for rejection, and price reasonableness is established by a method other than competition.

Alternatives namedYes
Price testedYes
FrequencyLow
ProcureAudit Sent separately
The challenge

Sent separately

Clauses went out by email and the purchase file holds nothing showing what the subcontractor accepted or when.

In the fileNo
ProvableWeakly
FrequencyHigh
ProcureAudit Attached to the award
With ProcureAudit

Attached to the award

The clause set travels with the subcontract order and is accepted alongside it, so the evidence is in the file by default.

In the fileYes
ProvableDirectly
FrequencyLow
A working checklist

Ten things to test on your own files first

Guides • Walkthrough

Ten things to test on your own files first

Pull a handful of recent files and test each against the same ten points before a reviewer does.

  • Competition sought, or a written justification
  • Price reasonableness documented
  • Approvals within delegated authority
SELF-REVIEW · FILE PO-41186
Office network refresh
2 TO FIX
01Competition sought
02Sole source justified
03Price analysis on file
04Cost or pricing data
05Approval in authority
06Flow-downs included
07Consent obtained
08Exclusion check
09Small business considered
10File complete at award
8 OF 10 PASS
#Test
01Does the file say why this supplier was chosen, in words written at the time?
02Does it name the alternatives considered, or only the one selected?
03Does it state which price evaluation technique was used?
04Are the comparators identified specifically rather than referred to in general?
05Where competition was absent, is price reasonableness established another way?
06Is the approver named, with a date, and at the right authority for the value?
07Does the file show which clauses were flowed down and that they were accepted?
08Where consent was required, does the evidence show it preceded the award?
09Do modifications carry their own reasoning and approvals, or only the parent award?
10Would a reader who was not involved reach the same conclusion from the file alone?

Defense and civilian reviews apply different criteria. Confirm which framework applies to your contracts and work from the current published guidance.

FAQ

Common questions about purchasing system reviews

What does a purchasing system review examine?
Two things: your written purchasing policies, and a sample of real purchase files tested against them. Consistency across buyers and periods is assessed throughout, since variation suggests individuals rather than a system.
How many criteria are there?
Defense reviews work from the criteria in DFARS 252.244-7001, which sets out 24 system criteria, interpreted through the DCMA guidebook. Civilian reviews use the factors in FAR Part 44.
Where do most findings come from?
The files rather than the policies. Selection reasoning missing, price evaluation with no visible method, thin sole source justifications and unevidenced flow-downs account for a large share.
Can we prepare by improving our policy document?
Only partly, and it is the half most teams over-invest in. A strong policy alongside files that do not meet it produces a gap finding, which is worse than a modest policy that is actually followed.
How far in advance should we start?
Well before any notice. What a file contains was determined when the award was placed, and reasoning that was never recorded cannot be convincingly reconstructed afterwards.
Should we tidy the files we think will be sampled?
No. Sample selection is not yours to predict, retrospective tidying tends to be visible, and it leaves the underlying process unchanged for the next review.
What is the single most valuable change?
Capturing selection reasoning at the point of decision. It is the most common gap, the hardest to fix afterwards, and the cheapest to prevent at the time.
Related reading

Other explainers and the pages they connect to

ProcureAudit What is a CPSR
RESOURCE

What is a CPSR

Who runs the review, what triggers one and what approval changes.

Learn more
ProcureAudit Sole source justification
RESOURCE

Sole source justification

What a defensible justification actually demonstrates.

Learn more
ProcureAudit Price analysis vs cost analysis
RESOURCE

Price analysis vs cost analysis

The two techniques and what the file should show.

Learn more

Run the checklist on ten of your awards

Bring them to the call and we will read them the way a reviewer would, including the ones you are confident about.

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