FFP Disclosure of component costs.

This may sound naive, but as I read the FAR and my current RFP (FFP for patented equipment with components which are all "commercial" items), I see nowhere that requires the Offeror to disclose in its Proposal actual estimated costs, and the profit that is expected from sales. But plastered everywhere I look is "Price/Cost Proposal."

This has me concerned since it appears to me to be counterintuitive with respect to the title. I realize that the Government can gain access to our records, quotes, etc to determine "Reasonableness" after a determination that we are "in the competitve range." It does mention that we need to describe our analysis, methods and "Results" thereof... But it refrains from coming out and asking for actual estimated costs & profit.

We have no subs except for Direct Material Suppliers, and none of them exceed the "simple acquisition threshold," so no certified price or costing data is required.

My question is: "Am I way off base, or have I interpreted the FAR/RFP correctly." I sure don't want to screw up now...

Many thanks to anyone who can help me out here.

Best,

bocajohn

boca,

What is your specific question? What is the estimated dollar value of the procurement, including options? What FAR provisions in the solicitation address price / cost information?

boca,

What is your specific question? What is the estimated dollar value of the procurement, including options? What FAR provisions in the solicitation address price / cost information?

Specifically I need to know if it is required to disclose our actual estimated costs for components & manufacturing expense; and whether we need to thereby disclose our profit. It is a FFP contract with no specific price limitations, but we will come in under $2MM total. 15.403 & 15.408 are mentioned as governing provisions.

It is legal for the contracting officer to ask you to break your price down into cost and profit. The FAR discourages the CO from asking for too much data, but does not prohibit such requests. See FAR 15.403-3. You can refuse, but it might cost you the business.

Specifically I need to know if it is required to disclose our actual estimated costs for components & manufacturing expense; and whether we need to thereby disclose our profit. It is a FFP contract with no specific price limitations, but we will come in under $2MM total. 15.403 & 15.408 are mentioned as governing provisions.

You may need to provide your actual estimated costs and profit. The answer depends upon your specific solicitation and its provisions, and the circumstances of the procurement. Chances are the solicitation contains the provision at FAR 52.215-20 -- Requirements for Certified Cost or Pricing Data and Data Other Than Certified Cost or Pricing Data. If so, read the provision to determine exactly what information the contracting officer is seeking from you.

If you must submit cost or pricing data because no exception applies, see FAR 15.408 at Table 15-2 -- Instructions for Submitting Cost/Price Proposals When Certified Cost or Pricing Data Are Required. Part I of the table -- General Instructions, requires you to provide your proposed cost; profit or fee. Part II of the Table 15-2 -- Cost Elements, requires a break down of your cost elements.

It is legal for the contracting officer to ask you to break your price down into cost and profit. The FAR discourages the CO from asking for too much data, but does not prohibit such requests. See FAR 15.403-3. You can refuse, but it might cost you the business.

I'm my exp, this is the bottom line answer. If the CO wants it, you give it to them - you can be 'dead right' in this situation by pushing back and saying you don't have to per xyz clause but you can forget about an award as they'll think you're hiding something (like excessive profit).

I've seen few times where a CO is pleased by a Contractor educating them on their on solicitation.

I'm my exp, this is the bottom line answer. If the CO wants it, you give it to them - you can be 'dead right' in this situation by pushing back and saying you don't have to per xyz clause but you can forget about an award as they'll think you're hiding something (like excessive profit).

I've seen few times where a CO is pleased by a Contractor educating them on their on solicitation.

Thanks to all! I get it. We will give it to them if they ask for it.

boca