Contract Planning and Advance Approval (CPAA)

Contract Planning and Advance Approval, abbreviated CPAA, is a Canadian federal procurement approval document and process. A buyer uses it to document a proposed procurement strategy and obtain the required approval before proceeding. The Government of Canada's buying guide describes it as the document used to obtain approval for contracts, standing offers and supply arrangements. See the CanadaBuys buyer's guide.

Once a CPAA is approved, contracting officers can issue contracts, standing offers or supply arrangements without going back to the approval authority, provided the procurement proceeds without significant changes to the approved strategy. A Government of Canada audit of land, aerospace and marine equipment procurement describes CPAA as a way to expedite procurement for this reason. Some older records spell the term "Contract Planning and Advanced Approval", but current CanadaBuys guidance uses "Advance Approval".

What a CPAA records

The CPAA is a planning document completed after the requirement has been identified and before the related solicitation or contract action goes ahead. According to CanadaBuys guidance, it captures:

• the approval or advance approval being requested;
• the procurement requirement and the options considered;
• the estimated total cost, including duties and taxes;
• the competitive or non-competitive procurement strategy;
• applicable policy issues or deviations;
• risks and mitigation measures;
• the evaluation criteria and selection methodology; and
• planned procurement milestones.

An approval authority can approve the procurement strategy without granting advance approval to enter into a contract. In that case, a further or revised approval document is required before contract award.

The $50,000 threshold in earlier PWGSC rules

The former Public Works and Government Services Canada Supply Manual set out when a CPAA was needed. Procurement strategies for requirements of $50,000 or more required approval through either a CPAA or a formal procurement plan. The Supply Manual required that approval before the department released a notice of proposed procurement, an Advance Contract Award Notice, a bid solicitation or a request for a standing offer.

The same manual stated that where there were no significant changes to the approved strategy, the CPAA process allowed contracting officers to award contracts without further reference to the approval authority.

How federal departments have used CPAA

Departments have applied the CPAA in different ways, as Office of the Procurement Ombudsman reviews show.

• Immigration, Refugees and Citizenship Canada (IRCC): The department required a CPAA after identifying a requirement and for each contract amendment. It was accompanied by a risk assessment, and high-risk procurements, including amendments exceeding 50% of the original contract value, went to the Procurement and Contracting Oversight Committee. Details are in the Procurement Ombudsman's review of IRCC.
• Natural Resources Canada: A CPAA was required when a request exceeded an individual's approval authority. It was recommended for first-time or sensitive procurements. See the review of Natural Resources Canada.
• Canada Border Services Agency (CBSA): The agency used CPAA forms alongside peer review and vertical review, then implemented a CPAA form in 2020. It later replaced that form with a Procurement Planning and Risk Assessment form, according to a later Procurement Ombudsman report.

What CPAA means for suppliers

The CPAA is an internal buyer-side approval document. Suppliers do not complete or sign it. Its effects still show up in the procurement process you bid on:

• A solicitation or request for a standing offer is not released until the required strategy approval is in place.
• The approved strategy can fix the evaluation criteria, pricing basis, mandatory requirements, point-rated criteria, solicitation method and milestones.
• If the buyer changes the strategy materially, revised approval may be needed before the solicitation proceeds or the contract is awarded, which can affect timelines.

Bid teams should read the solicitation documents closely, because the evaluation approach and milestones they set out come from the approved strategy.