Excessive Administrative Burden from 'Kitchen Sink' Flow-Down Practices
Definition
Primes overload subcontracts with all FAR/DFARS clauses—even non-mandatory ones—to simplify their compliance, imposing unnecessary complexity and controls on subcontractors. This drives up administrative costs for contract drafting, training, monitoring, and dispute resolution across the supply chain. New DFARS rules (252.244-7000) force overhaul of these practices, revealing embedded cost inefficiencies.
Key Findings
- Financial Impact: $Significant increase in supply chain management overhead
- Frequency: Per subcontract award and annual review
- Root Cause: 'Kitchen sink' templating ignores clause applicability triggers, leading to over-compliance
Why This Matters
This pain point represents a significant opportunity for B2B solutions targeting Defense and Space Manufacturing.
Affected Stakeholders
Supply Chain Managers, Legal Counsel, Subcontractor Compliance Teams
Deep Analysis (Premium)
Financial Impact
$1.2M-$4M annually (across NASA centers); delayed mission launches costing $100K-$500K per day; supplier cost escalation requests after contract award ($200K-$2M per major subcontract); compliance remediation audits • $1.5M-$3.8M annually per DHS contractor (legal review, subcontract rework, vendor pool attrition, administrative labor, potential non-compliance findings) • $1.8M-$4.2M annually per NASA center/prime (labor cost of re-negotiating subcontracts, legal review fees, reduced competition due to perceived subcontractor burden, potential audit findings, delays in contract award)
Current Workarounds
Collect subcontract files; compare flowdown clauses to regulation; prepare email response to DCAA; create audit workpaper in Word/Excel • Configuration Manager queries Procurement via email; manual cross-reference of flowdown requirements; update Excel tracking sheet; notify downstream subcontractors via email of changes • Configuration Manager updates Excel tracking sheet; email notification to Procurement and Legal; manual cross-reference of impacted flowdown clauses; version control via shared drive
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Methodology & Sources
Data collected via OSINT from regulatory filings, industry audits, and verified case studies.
Related Business Risks
Failure to Properly Flow-Down Mandatory FAR/DFARS Clauses Leading to Audit Failures
Logistical Bottlenecks in CMMC/NIST Flow-Down Verification and Enforcement
Delayed Subcontractor Payments in Progress Payment Chains
Small Business Exclusion from Cost-Based Progress Payments
Proposal Quality Defects Driving Rework and Lost Awards
Loss of Current and Future Contract Revenue from Cyber / DFARS Non‑Compliance in Bid Phase
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