FAR 15.408 Table 15-2 Item F. Identification of Incurred Costs in Cost Proposal

You need to include all costs that will serve as the basis for the new contract's price.

I'm still confused.  We would not be asking for reimbursement of incurred costs that are not included in the Scope of Work for the proposal.  The costs we are submitting for reimbursement are the ones applicable to the proposed Scope of Work. So, do we need to identify past costs associated with previous development efforts of the R&D project which is not part of the proposed Scope of Work?

You need to include all costs that will serve as the basis for the new contract's price.

BTR2562 said:

do we need to identify past costs associated with previous development efforts of the R&D project which is not part of the proposed Scope of Work?

This raises the question of whether the past costs would be considered cost or pricing data in regard to the new contract.  If they meet the definition of cost or pricing data, they need to be disclosed.  If they do not meet the definition of cost or pricing data, they do not need to be disclosed.

BTR2562 said:

I'm still confused.  We would not be asking for reimbursement of incurred costs that are not included in the Scope of Work for the proposal.  The costs we are submitting for reimbursement are the ones applicable to the proposed Scope of Work. So, do we need to identify past costs associated with previous development efforts of the R&D project which is not part of the proposed Scope of Work?

No. Just the costs that are the basis of your proposed price. This would apply if you had started work under an undefinitized contract action, for example.

BTR2562 said:

I'm still confused.

If, in anticipation of receiving the contract, you incurred costs for work that will be required by the prospective contract, i.e., initial costs or precontract costs (see FAR 31.205-32), then you must identify them as such costs.

BTR2562 said:

…previous costs have been incurred in the development of the product, which is not part of the continued R&D work that is proposed to be performed in the technical and cost proposal.

I think BTR is saying that these costs are not part of the technical or cost proposal for the work included in the R&D contract. Thus, they aren’t costs for part of the work to be required by or to be included in the contract. They don’t appear to form the basis for the contract price (I.e., aren’t included in the contract price). Is that correct, BTR?

So, if they don’t form the basis for the contract price, see ji’s response.

Joel, you are correct. Thanks!

Vern Edwards said:

If, in anticipation of receiving the contract, you incurred costs for work that will be required by the prospective contract, i.e., initial costs or precontract costs (see FAR 31.205-32), then you must identify them as such costs.

Vern is correct, in my view.

Contractors may have incurred costs in advance of contract award. One reason might be to shorten the delivery schedule. Another reason might be because the contractor routinely builds to inventory so as to have a ready supply of whatever.

If the costs incurred by the contractor pre-award have already been reimbursed (e.g., IR&D) then no need to disclose them.

here_2_help said:

Vern is correct, in my view.

Contractors may have incurred costs in advance of contract award. One reason might be to shorten the delivery schedule. Another reason might be because the contractor routinely builds to inventory so as to have a ready supply of whatever.

If the costs incurred by the contractor pre-award have already been reimbursed (e.g., IR&D) then no need to disclose them.

“31.205-32 Precontract costs.

Precontract costs means costs incurred before the effective date of the contract directly pursuant to the negotiation and in anticipation of the contract award when such incurrence is necessary to comply with the proposed contract delivery schedule. These costs are allowable to the extent that they would have been allowable if incurred after the date of the contract (see  31.109)”

The costs referenced by the OP aren’t part of the cost proposal for the work that will be required under the contract.

joel hoffman said:

The costs referenced by the OP aren’t part of the cost proposal for the work that will be required under the contract.

Yes. Agreed. That's why Vern is correct. He identified the costs that must be reported in the Table. If the OP's costs are not those costs, then they don't have to be reported.