Why Spreadsheets Keep Failing 

Most compliance officers didn’t choose the spreadsheet. It’s what was already open the day the first contract with a flowdown clause showed up, and it just kept growing from there. One tab became five. Five became a workbook nobody wants to open on a Friday.  The trouble is a spreadsheet doesn’t fail the way a…

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The Great Compliance Handoff

Why Shifting the Burden to Contractors Made Defense Manufacturing Better  For most of the last eighty years, the story of aerospace and defense compliance has quietly been rewritten around one central question: Who is responsible for quality? The plot twist is that the answer has ultimately been good for everyone.  If you have spent any…

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How DCMA Surveillance Works and What It Means for Your Operations

Many defense manufacturers think of the Defense Contract Management Agency (DCMA) as the agency that arrives when it is time for an audit or formal review.   That is only part of the picture.   For manufacturers with active Department of Defense contracts, DCMA oversight may be an ongoing part of doing business. The agency does not…

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How to Write a Compliant Subcontract for a Commercial Item Under FAR Part 12 

The FAR technically retired the term “commercial item.” A few years back it split into two defined terms, commercial product and commercial service, both at FAR 2.101. Everyone in the industry, including us in the title of this post, still says “commercial item” out of habit. That’s fine as shorthand. The problem is when a subcontract template still reflects the old, looser…

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