Jacques - Correct, I work with DOD which requires me to make a separate price reasonableness determination. I agree with you that requesting subcontractor information is gathering other than cost or pricing data and putting on the road to a cost analysis, where only a simple price analysis is required.
The other Contracting Officer is very wrapped up in ensuring that the Prime vendors are not including an unreasonable amount of profit on the subcontractor rates. I'm not very concerned by this, since I'm competing a small business set aside and have received multiple quotes and feel confident in making a reasonableness determination using the price analysis techniques in FAR 15.404-1(b ) (2).
As Vern stated, I haven't found anything within the MAS handbook, FAR, or DFARS that would require me to dig any deeper into the rates. Most of my Acquisitions have been much larger ($500 Million +) and under FAR Part 15, so I wanted to stop by here for a sanity check, since I don't use the FSS very often. Thanks everyone!