FAR 44.304—Surveillance.
Plain-English Summary
FAR 44.304 explains how the Government monitors a contractor’s purchasing system after award. It requires the Administrative Contracting Officer (ACO) to maintain enough surveillance to determine whether the contractor is effectively managing its purchasing program, and it requires that surveillance be carried out under a written or otherwise defined plan developed by the ACO with help from subcontracting, audit, pricing, technical, or other specialists as needed. The section identifies the major areas the plan should cover: preaward, postaward, performance, and contract completion phases, as well as other contractor operations that affect purchasing and subcontracting. It also requires the Government to check whether the contractor’s corrective actions from prior Government recommendations are actually working. Finally, it directs the Government to avoid duplicative reviews of the same areas by CPSR teams and other surveillance personnel, so oversight is effective without unnecessary burden or overlap. In practice, this section is about making surveillance targeted, coordinated, and useful enough to protect the Government’s interests while giving contractors clear expectations about how their purchasing systems will be reviewed.
Key Rules
Maintain adequate surveillance
The ACO must keep a sufficient level of oversight to determine whether the contractor is effectively managing its purchasing program. This is an ongoing monitoring responsibility, not a one-time review.
Use a surveillance plan
Surveillance must be performed under a plan developed by the ACO. The plan should organize how reviews will be conducted and what areas will be examined.
Use specialist support as needed
The ACO may rely on subcontracting, audit, pricing, technical, or other specialists to help develop and carry out the plan. The rule recognizes that purchasing-system oversight often requires multiple disciplines.
Cover the full purchasing lifecycle
The plan should address pertinent phases of the contractor’s purchasing system, including preaward, postaward, performance, and contract completion. It should also include other operations that affect purchasing and subcontracting.
Review corrective actions
The plan should include follow-up on the effectiveness of contractor corrective actions taken in response to prior Government recommendations. Surveillance is meant to verify that fixes actually resolved the issue.
Avoid duplicate reviews
The Government should avoid duplicative reviews of the same areas by CPSR and other surveillance monitors. Oversight activities should be coordinated to reduce burden and prevent wasted effort.
Responsibilities
Administrative Contracting Officer (ACO)
Maintain sufficient surveillance over the contractor’s purchasing program, develop the surveillance plan, coordinate with specialists as needed, ensure the plan covers relevant phases and operations, and verify the effectiveness of corrective actions from prior Government recommendations.
Subcontracting, audit, pricing, technical, and other specialists
Assist the ACO in developing and/or executing the surveillance plan when their expertise is needed to evaluate the contractor’s purchasing system and related operations.
Contractor
Operate a purchasing program that can withstand Government surveillance and implement corrective actions when the Government identifies deficiencies; the contractor should also be prepared for follow-up reviews of those corrective actions.
Government surveillance monitors / CPSR reviewers
Coordinate oversight activities so reviews are not duplicative and so the same areas are not examined repeatedly by multiple Government functions without need.
Practical Implications
This section pushes the ACO to be deliberate and risk-based: surveillance should focus on areas that matter to purchasing-system effectiveness, not just check boxes.
Contractors should expect follow-up on prior findings; submitting a corrective action plan is not enough if the Government later determines the fix was ineffective.
Coordination matters. If CPSR, audit, and ACO surveillance are not aligned, contractors may face overlapping requests and inconsistent findings, which this rule is designed to prevent.
A weak or informal surveillance plan can lead to missed problems in subcontracting controls, approval processes, or postaward purchasing practices.
For contractors, the practical takeaway is to keep purchasing-system documentation, corrective actions, and internal controls organized and current, because surveillance may span the full contract lifecycle and related operations.
Official Regulatory Text
(a) The ACO shall maintain a sufficient level of surveillance to ensure that the contractor is effectively managing its purchasing program. (b) Surveillance shall be accomplished in accordance with a plan developed by the ACO with the assistance of subcontracting, audit, pricing, technical, or other specialists as necessary. The plan should cover pertinent phases of a contractor’s purchasing system (preaward, postaward, performance, and contract completion) and pertinent operations that affect the contractor’s purchasing and subcontracting. The plan should also provide for reviewing the effectiveness of the contractor’s corrective actions taken as a result of previous Government recommendations. Duplicative reviews of the same areas by CPSR and other surveillance monitors should be avoided.