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Daniel Chalfant

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  1. Don, Thank you for pointing out the contractor burdens associated with this local clause. It is a tremendous burden to the contractor and the subcontractor. Since subcontractors do not provide proprietary data to the prime contractor, for a CPFF sub, it required TWO Invoices each month. One invoice is sanitized for the prime, the Second invoice includes the required detail for the COR. The Sub must submit their invoices directly to the COR, who has no privy of contract. At Accenture, we tried to solve this problem by using Time & Material subcontracts. A T&M invoice meets both requirements and the second invoice can be a copy of the first. The CO however, refused to provide consent for T&M subcontracts. The only viable solution seem to be to pass the additional cost of this clause on to the government.
  2. All Govies, As a Cost/Price Analyst for a Government Contractor, I would love to perform Cost of Price Analysis on all subcontracts at any value, and provide the results to the Government on every proposal we prepare. Unfortunately, we do not have unlimited budget and unlimited resources to perform all this work on proposals we may never win, and never place any actual "subcontracts". I suggest we all use some common sense and concentrate on the cost drivers, not the $42k widgets. The checklist at DFARS 252.215-7009 seems to recognize this fact. I think Steveatus has a logical and sensible approach to this requirement.
  3. Post Script, 2014. Both Don and Vern were correct with their responses above, at the time they responded. Since then, some things have changed: First, Vern sated "None of the defective pricing or cost or pricing data clauses in FAR 52.215 mention Table 15-2". This was changed in October 2010, when FAR 52.215-12 was revised to include reference to FAR 15.408, Table 15-2. Second, in Janurary 2014, DFARS added 252.215-7009 Proposal Adequacy Checklist (JAN 2014). Item 17 on this checklist asks "Is there a price/cost analysis establishing the reasonableness of each of the proposed subcontracts included with the proposal? If the offeror’s price/cost analyses are not provided with the proposal, does the proposal include a matrix identifying dates for receipt of subcontractor proposal, completion of fact finding for purposes of price/cost analysis, and submission of the price/cost analysis?". Dan
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