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About gjhall23

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  1. Thank you Vern. My wife would agree with you that I am an idiot so thank for the daily dose of humility. I must say I did read your previous post incorrectly when you made mention of 'audit'. I was multitasking and read it as 'analysis'. My mistake. The real issue I am having is the subcontractor will not provide me with any cost or pricing data (or even how it calculated its indirect cost rates) which makes the task of performing a cost analysis extremely difficult. An audit is not essential- that is true, yet without one and the lack of DCAA/DCMA verbally providing me anything I was just asking if others had been in similar circumstances and how they approached it.
  2. Vern - you mention that an audit is not absolutely essential. I've never heard that. Can you elaborate? I agree that $800k is not alot but per our approved CPSR procedures we are required to perform a cost analysis. I like what you mention regarding asking the sub how they calculate their indirects or requesting verbal info from DCAA; however, since I do not have the cost/price information the sub has provided would it be prudent for me to accept the cost/price certification?
  3. Vern you brought up a good point that I should have clarified. This was a field pricing assist request that was turned down. The other details I should mention are that the proposal in question was for roughly $800k and was T&M. So this does not cross the thresholds you referenced. But my questions remains - when the proposal crosses the TINA threshold but not the DFARS PGI 215.404-2(a)(ii) thresholds and the subcontractor will not provide cost or pricing data to anyone but the government for competitive reasons what alternatives do I have if the government refuses to perform the audit? Go back and compete the effort?
  4. If DCAA/DCMA refuses to perform a subcontract cost/price analysis under a Prime Contract subject to TINA (certification required) what options are available to determine fair and reasonableness? The options I have heard (and my rebuttal to each) are: 1. Request the subcontract to provide 'data other than cost/pricing''; however I believe this to be insufficient because a cost/price certification is needed from the subcontractor 2. Have a mutually agreeable 3rd party perform the cost/price analysis (this can be costly); or 3. Reach out to the Contracting Officer and rely on she/he to perform the analysis Does anyone have any experience with a similar scenario?