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To provide more regulatory support for Vern’s point, FAR 2.101 defines “line item” as “the basic structural element in a procurement instrument that describes and organizes the required product or service for pricing, delivery, inspection, acceptance, invoicing, and payment.” Just as Vern described, line items are for the required end item or service, and require inspection and acceptance. ODCs are not the required end items or service, they are costs associated with providing the product or service. They do not require inspection and acceptance. If you have made/seen ODC CLINs in the past, I hope that you will not in the future.

We get a lot of large procurements in my office. Doing the required cost analyses for subcontractors over the current threshold for the requirement of certified cost or pricing data becomes very laborious, with ultimately little value added. The TINA threshold will change to $2 million soon, but that does not alleviate the issue much. One thought would be to add an alternate threshold for the requirement of certified cost or pricing data for subcontractors at FAR 15.403-4(a)(1)(ii) to something like: “The award of a subcontract at any tier, if the contractor and each higher-tier subcontractor were required to furnish cost or pricing data. The CCPD threshold for subcontractor(s) is increased to $5,000,000 when: (1) The total contract value of the prime contract is in excess of $500,000,000, and (2) The suppliers that are valued individually below $5,000,000 are added together, the total must equal less than 10% of the total proposed price.” This would significantly reduce evaluation workload while ensuring that we still evaluate the bulk of the proposal. Per the FAR, price analyses would still be required for the subcontractors less than $5M.

Thanks Vern, I understand it now. That paragraph had been bothering me a lot lately. There is a new proposed DFARS change that is adding provision 252.215-70XX Requirements for Certified Cost or Pricing Data and Data Other Than Certified Cost or Pricing Data. In both the Basic and Alternate I, paragraph (e) states "The Offeror shall require all prospective subcontractors above the simplified acquisition threshold in FAR part 2 to adhere to the requirements of paragraph © of this provision when determining that the proposed prices from prospective lower-tier subcontractors are fair and reasonable" Paragraph © is "Requirements for certified cost or pricing data". I submitted a comment to regulations.gov asking why this provision states all lower tier subs greater than SAT have to adhere to the requirements of certified cost or pricing data rather than all subs greater than the truthful cost or pricing data threshold. In light of your prior reply, I still think the proposed DFARS provision is in error, because it would be the call of the HCA to determine if certified cost or pricing data can be required, and the provision paragraph is talking specifically about subcontractors and their lower-tier subcontractors. What are your thoughts? Is there something I am missing? The proposed change is located at http://www.regulations.gov/#!documentDetail;D=DARS_FRDOC_0001-0831 for reference.

Why does FAR 15.403-1(a) state that "Certified cost or pricing data shall not be obtained for acquisitions at or below the simplified acquisition threshold" while FAR 15.403-4(a)(1) states that "the threshold for obtaining certified cost or pricing data is $700,000"? Acquisitions at or below the simplified acquisition threshold will not exceed $700,000. Am I incorrect in thinking that FAR 15.403-1(a) is unnecessary?