How many Corrective Action Request can be Issued by DCMA for a single issue?

[Roberts2600]

Our QAR found a nonconformance in which we didn't do a PLT and issued a Corrective Action Request (CAR). We answered the CAR and reviewed a sample of several other contracts to determine we didn't have a systemic issue. We believed we this was a one off issue and submitted our answer, CAP, to the CAR. While the CAR was still open our QAR found another PLT that was not flowed down to us from the customer in a deliverable order. This PLT was in the BASE contract. He then issued another CAR, number 2, for a PLT issue and also rejected our original CAR, number 1. It seems like he would not be able to issue a second CAR if the original was still open and thus should have just rejected the first CAR. Do we have any ground to fight the second CAR since it was still open and pending review? Are there any DFAR or DCMA policies that say they shouldn't issue a second if the first is still open?

 

[Coury Ferguson]

Our QAR found a nonconformance in which we didn't do a PLT and issued a Corrective Action Request (CAR). We answered the CAR and reviewed a sample of several other contracts to determine we didn't have a systemic issue. We believed we this was a one off issue and submitted our answer, CAP, to the CAR. While the CAR was still open our QAR found another PLT that was not flowed down to us from the customer in a deliverable order. This PLT was in the BASE contract. He then issued another CAR, number 2, for a PLT issue and also rejected our original CAR, number 1. It seems like he would not be able to issue a second CAR if the original was still open and thus should have just rejected the first CAR. Do we have any ground to fight the second CAR since it was still open and pending review? Are there any DFAR or DCMA policies that say they shouldn't issue a second if the first is still open?

Not that I am aware of, that would be under the discretion of your DCMA Supervisor Quality Assurance Representative (SQAR).

My suggestion would be to discuss this with the QAR or SQAR and ask them. If the CAP hasn't been submitted, accepted or rejected then you may have some common sense grounds with the DCMA.

If you are thinking it could be considered double jeopardy that won't be a good ground to challenge on.

Just my opinion

 

[JNIKQ]

Our QAR found a nonconformance in which we didn't do a PLT and issued a Corrective Action Request (CAR). We answered the CAR and reviewed a sample of several other contracts to determine we didn't have a systemic issue. We believed we this was a one off issue and submitted our answer, CAP, to the CAR. While the CAR was still open our QAR found another PLT that was not flowed down to us from the customer in a deliverable order. This PLT was in the BASE contract. He then issued another CAR, number 2, for a PLT issue and also rejected our original CAR, number 1. It seems like he would not be able to issue a second CAR if the original was still open and thus should have just rejected the first CAR. Do we have any ground to fight the second CAR since it was still open and pending review? Are there any DFAR or DCMA policies that say they shouldn't issue a second if the first is still open?

Sometimes the QARs get trigger happy and want to issue CARs to build up their numbers. Believe me in all my years dealing with the Government, the relationship you build with your assigned QAR will go a long way in avoiding undeserved CARs that waste a lot of time. If the QAR did his homework the CAR, the CAR should have been written up against the Quality Management System. This would have captured a weakness in the system of identifying all contractual requirements. If they wrote it up as a non-compliance to one specific contract, then you have a QAR who isn't doing you justice. I tried to encourage my QARs to act quickly in closing out a CAR that has been responded to in a timely manner. If they've taken more than a week a deem your CA/PA acceptable, then they're not doing their job. Bottom line, they shouldn't issue multiple CARs for the same deficiency IF your CA/PA clearly identified the root cause and part of the fix is to scrub the system to see if anymore contracts are affected.