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Andy

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  1. Background: To-date our company has no CAS covered contracts and we have never submitted a CAS disclosure statement previously. Our company recently submitted a proposal which was >$50M and in a NAICS where we are considered a large business. We are concerned that we may have made a mistake by not submitting a disclosure statement with the proposal. In our proposal Section K certification for FAR 52.230-1 Part I we selected the “Certificate of Monetary Exemption” option. When we were completing the proposal we thought this was the correct action since the words in this paragraph of the clause describe our situation. We thought that we were exempt from including the disclosure statement with our proposal, and that we were required to submit only before award or shortly after (see CFR 9903.202(b)). However, since submitting our proposal, it has come to our attention that the FAR/CFR regulations can be interpreted in a way which requires that the disclosure statement be submitted with the proposal. Questions: Were we required to submit the CAS disclosure statement with our proposal, or was our initial interpretation correct and its due only before award or shortly after in accordance with CFR 9903.202(b)? Do you think the contracts office will/could consider us non-responsive and throw out our proposal for this sole issue? I assume that if we submitted a disclosure statement now that it could not be included in the evaluation. Is that correct? Reference Materials: 1. FAR 52.230-1 2. CFR Part 9903 – Contract Coverage: 3. CFR Part 9904 – Cost Accounting Standards: https://www.gpo.gov/fdsys/pkg/CFR-2010-title48-vol7/xml/CFR-2010-title48-vol7-part9904.xml
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