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Patrick Mathern

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Posts posted by Patrick Mathern

  1. Like some of the other respondents, this is a little confusing to me. Could you clarify this: Are incurred costs being requested in order to determine what you're due as a result of the termination? Or are the incurred costs being requested in support of Table 15-2, which is used in proposals?

    I'm going to go out on a limb and guess that it's the latter. Since your customer has a fixed bucket of dollars, they're going to be required to substantiate that the value of the work incurred plus the value of the new work is truly worth what you're charging.

    If that's the case, you're in the driver's seat on this one. Speaking as simply as possible: Provide actual hours and actual material dollars. They can burden all of that using the bid rates that you provided previously.

  2. I'd like to re-open this conversation under a slightly different light. Is there anyone out there in private industry that uses or has seen a contract administration system that allows for effective organization and management of prime contracts? I have clients that use a mix of Windows File Manager, Sharepoint, and one that says they use GovWin for this purpose (though I haven't seen this myself). Anybody have experience with other systems that they can share?

    Thanks in advance!

  3. We conduct cost/price analysis on behalf of federal primes and subs and have never flinched in using prior price history as a basis for price analysis (assuming, of course, that the historical price can be substantiated as fair and reasonable as well as a suitable basis in and of itself, a whole other topic of conversation...)

    Recently, we took a closer look at FAR 15.404-1( B)(2), which reads as follows:

    The Government may use various price analysis techniques and procedures to ensure a fair and reasonable price. Examples of such techniques include, but are not limited to, the following:

    (ii) Comparison of the proposed prices to historical prices paid, whether by the Government or other than the Government, for the same or similar items. This method may be used for commercial items including those “of a type” or requiring minor modifications.

    Am I reading this wrong or does this say analysis based on historical pricing is only valid for commercial items? Let's say the contractor purchases items which required cost analysis (subject to TINA). Three months later, a new requirement pops up (under TINA threshold but over simplified acquisition). Since these are not commercial items, would this prior procurement and cost analysis not be a suitable basis for determining price reasonableness (of course after adjusting for quantity and passage of time)?

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