CAS and Commercial SubContract >$7.5m
Started by Beantown_Contracts · Feb 15, 2013 · 4 replies
- BOriginal post
Beantown_Contracts
Feb 15, 2013 · 13y ago
Situation: A small business subcontractor is submitting a proposal in excess of $7.5m to a large DoD prime.
The SB subcontractor will be asserting commerciality on this FFP proposal.
Prime is demanding a DCAA compliant costing submission. (redacted to them, unredacted to the DoD customer)
Given that the subcontractor is: a) a small business (CAS exempt) and
submitting a Commercial (2.101), does the Prime or the DoD customer have the right to demand a DCAA compliant costing submission.Responses appreciated.
B_C
- D
Don Mansfield
Feb 15, 2013 · 13y ago
What do you mean by "DCAA compliant costing submission"? Does that mean it has to be in the format of FAR Table 15-2?
- B
Beantown_Contracts
Feb 15, 2013 · 13y ago
Don,
Thank you for the question.
Customer is requesting labor rate build up. The Subk is not set up to provide accurate direct and indirect rates. The labor rates are on a published price list with substantial commercial type sales to affirm commerciality.
V/R,
B_C
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Retreadfed
Feb 15, 2013 · 13y ago
BC, look at MRD 11-PSP-017®, dated Sep. 29, 2011. This is the DCAA audit guidance on this point and can be found under the open audit guidance tab at the DCAA website.
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here_2_help
Feb 15, 2013 · 13y ago
BC,
Just to add to what Retreadfed said, the requirement to supply cost or pricing data in FAR Table 15-2 format has nothing to do with CAS, and everything to do with FAR Part 15 requirements.
If the company is asserting that its product meets the definition of a commercial item -- and can back that assertion up -- then it does not have to submit certified cost or pricing data. It may have to submit uncertified cost or pricing data, or information other than cost or pricing data. If it is not submitting certified cost or pricing data, then it does not have to follow the FAR Table 15-2 format.
The company needs to help its prime establish price reasonableness, somehow. If it's not prepared to do that, then it shouldn't be in the government contracting business. At best, it should publish a product catalog and tell the prime contractor to submit an order via the company's internet ordering website. At worst, it should find another customer.
On the other hand, I bet that's a big order for the small business. I wonder if the lure of big money is sufficient to force a cultural change?
Hope this helps.