Contract Planning & Advance Approval (CPAA)

Contract Planning and Advance Approval (CPAA) is a Government of Canada procurement approval document and process. A buying organization uses it to document a proposed procurement strategy and obtain the required approval before it proceeds with specified procurement activities. According to CanadaBuys buyer guidance, a CPAA can support the issuance of contracts, standing offers and supply arrangements.

CPAA is an internal control used in the administration of contracting authority. It sits within the federal procurement-approval framework, alongside the formal Procurement Plan, which is used for procurements that need a different level or form of approval. Suppliers do not complete it. They see its effect in how and when a solicitation, contract or amendment is released.

What a CPAA records

The CPAA gives the approval authority the information it needs to decide. Per CanadaBuys, the document covers:

• the proposed procurement strategy and the approval action being sought, including whether approval or advance approval is requested;
• the requirement, the options considered and the total estimated cost, including duties and taxes where applicable;
• the proposed solicitation method and, for a non-competitive procurement, the legal basis for the exception to competitive bidding;
• the evaluation criteria and selection methodology;
• policy issues, risks and mitigation measures; and
• significant procurement milestones.

Strategy approval versus advance approval to contract

The approval authority can approve the procurement strategy while withholding advance approval to enter into the contract. In that case the buyer must obtain a subsequent or revised approval document before it awards the contract. For a supplier, this explains why a solicitation can proceed while contract award still depends on a further internal approval.

Archived guidance from the former PWGSC Supply Manual set the sequence. The archived federal procurement guidance states that the CPAA or formal Procurement Plan had to be approved before the buyer released a Notice of Proposed Procurement, an Advance Contract Award Notice, a bid solicitation or a request for a standing offer.

How federal organizations apply CPAA

Use of the CPAA is not limited to one department. Several federal reviews and audits describe it in practice:

• Task authorization contracts: the CPAA or formal procurement plan must address the suitability of the method, the proposed financial limits, client roles and responsibilities, and contract monitoring. See the CanadaBuys task authorization guidance.
• Immigration, Refugees and Citizenship Canada: the Office of the Procurement Ombudsman reported that the contracting officer completes a CPAA after identifying the requirement. A CPAA is also required for each contract amendment, and it summarizes the requirement, contract history, amendments, strategy, risks and the officer's comments.
• Canada Border Services Agency: a Procurement Ombudsman review states that CBSA implemented a CPAA form on November 15, 2020, and made it a mandatory approval step with the implementation of Ariba.
• Natural Resources Canada: a Procurement Ombudsman review states that a CPAA was mandatory when a procurement request exceeded an individual's approval authority, and recommended for first-time or sensitive procurements.
• Audit testing: an NRCan audit identified the presence of a CPAA or Contract Planning document as a procurement-file control, tested alongside Section 32 approval and other compliance documentation.

What CPAA means for a supplier bidding on Canadian public contracts

CPAA is an internal buyer approval process. It is not a document a supplier submits with a bid, and the sources identify no general supplier obligation to complete one. Its practical effect is that the buyer must finish and approve its strategy before releasing a solicitation and, where required, before awarding or amending a contract.

Suppliers should follow the resulting solicitation, evaluation, pricing, security, contractual and amendment requirements. Expect an amendment to require its own buyer approval, and expect task-authorization contracts to carry the financial limits and monitoring controls set during planning. Opportunities are published on CanadaBuys.