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Amart

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About Amart

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  1. Assertions notwithstanding, contracting officers have a "no data, no F&R determination, no contract" stick when it comes to cost or pricing data like they currently have with commercial item determinations. I notice you responded to the first part of my post but not the part about the incentive to stonewall. How would you mitigate/counter that under your proposed regime?
  2. You mean those documents that contractors need to submit to demonstrate that their pricing is fair and reasonable or else they doesn't get a contract? Kind of like how they currently have to submit documents to prove that its product is commercial? Under the burden-shifted regime, the contractor would be incentivized to stonewall.
  3. I disagree with this suggestion. As it currently stands, the Contractor is in the best position to provide evidence in support of its assertions that its product fits one of the eight definitions of commercial item (e.g. sales figures, marketing documents, internal emails). If the burden switched to the Government, you'd be forcing the party without any of that data to prove a negative.
  4. Vern, It has been a while, but if I remember correctly, the old Army Single Face to Industry system fit the exception; the pertinent information would be kept on ASFI with a link posted to FBO.
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