Report Fair & Reasonable for FFP Contracts in Contract Award Process Posted February 10, 2016 I believe that the short answer to your question is no. Are you considering subcontracting cost and subcontractor quote to be the same? I do not believe so. My understanding is that the subcontracting cost will include the prime's profit; whereas, the subcontractor quote is just that. Depending on the terms of the contract, FAR Part 15.404-3 might apply. If so, then the contracting officer is responsible for the determination of a fair and reasonable price for the prime contract, including subcontracting costs (15.404-3(a)). Even when 15.404-3 does not apply, the CO might be trying to use data other than certified cost or pricing data provided by the offeror (prime) as the means to determine price fair and reasonableness. See 15.404-1(b)(2)(vii). There is nothing that prevents the CO from removing "certified" from the instructions and utilizing FAR Table 15-2. Excerpt from Table 15-2- II. -- Cost Elements A. Materials and services. Provide a consolidated priced summary of individual material quantities included in the various tasks, orders, or contract line items being proposed and the basis for pricing (vendor quotes, invoice prices, etc.). Include raw materials, parts, components, assemblies, and services to be produced or performed by others. For all items proposed, identify the item and show the source, quantity, and price. Conduct price analyses of all subcontractor proposals. Conduct cost analyses for all subcontracts when certified cost or pricing data are submitted by the subcontractor. Include these analyses as part of your own certified cost or pricing data submissions for subcontracts expected to exceed the appropriate threshold in FAR 15.403-4. Submit the subcontractor certified cost or pricing data and data other than certified cost or pricing data as part of your own certified cost or pricing data as required in paragraph IIA(2) of this table. These requirements also apply to all subcontractors if required to submit certified cost or pricing data. (1) Adequate Price Competition. Provide data showing the degree of competition and the basis for establishing the source and reasonableness of price for those acquisitions (such as subcontracts, purchase orders, material order, etc.) exceeding, or expected to exceed, the appropriate threshold set forth at FAR 15.403-4 priced on the basis of adequate price competition. For interorganizational transfers priced at other than the cost of comparable competitive commercial work of the division, subsidiary, or affiliate of the contractor, explain the pricing method (see FAR 31.205-26(e)). (2) All Other. Obtain certified cost or pricing data from prospective sources for those acquisitions (such as subcontracts, purchase orders, material order, etc.) exceeding the threshold set forth in FAR 15.403-4 and not otherwise exempt, in accordance with FAR 15.403-1(b) (i.e., adequate price competition, commercial items, prices set by law or regulation or waiver). Also provide data showing the basis for establishing source and reasonableness of price. In addition, provide a summary of your cost analysis and a copy of certified cost or pricing data submitted by the prospective source in support of each subcontract, or purchase order that is the lower of either $13.5 million or more, or both more than the pertinent cost or pricing data threshold and more than 10 percent of the prime contractor’s proposed price. Also submit any information reasonably required to explain your estimating process (including the judgmental factors applied and the mathematical or other methods used in the estimate, including those used in projecting from known data, and the nature and amount of any contingencies included in the price). The Contracting Officer may require you to submit cost or pricing data in support of proposals in lower amounts. Subcontractor certified cost or pricing data must be accurate, complete and current as of the date of final price agreement, or an earlier date agreed upon by the parties, given on the prime contractor’s Certificate of Current Cost or Pricing Data. The prime contractor is responsible for updating a prospective subcontractor’s data. For standard commercial items fabricated by the offeror that are generally stocked in inventory, provide a separate cost breakdown, if priced based on cost. For interorganizational transfers priced at cost, provide a separate breakdown of cost elements. Analyze the certified cost or pricing data and submit the results of your analysis of the prospective source’s proposal. When submission of a prospective source’s certified cost or pricing data is required as described in this paragraph, it must be included as part of your own cost or pricing data. You must also submit any data other than certified cost or pricing data obtained from a subcontractor, either actually or by specific identification, along with the results of any analysis performed on that data. Essentially, I believe that there are times when the prime is responsible for providing their subcontracting cost. For all other times, it might be in the primes best interest to provide their subcontractor's quote. Especially if the outcome of the modification, assuming this is post award, will increase the cost of the contract. If so, the burden is on the prime to demonstrate that their price is fair and reasonable. Otherwise, the CO might not have enough information to determine that the price is fair and reasonable. Hope this helps.