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  1. Scenario: Government has a prime IDIQ contract with a $800M ceiling under which CPFF/LOE Task Orders are issued. The Task Orders are primarily for labor hours (non-commercial services). Prime contractor is stating that they estabished T&M contracts (reasonableness based on price analysis) with their subcontractor suppliers for the length of the prime IDIQ contract at the time of the initial IDIQ award (10 months ago). A new Task Order is being solicited by the Government valued at $100M. Cost or Pricing data submitted by the prime indicates they are proposing subcontract cost from one subcontractor @ $20M. Prime is stating that because they have an established subcontract already in place, they can certify to their proposed costs and do not have to cause the subcontractor to submit certified cost or pricing data to the government, even though they are proposing subcontract costs (and intend to issue a Task Order under their T&M agreement) that exceeds the $12.5M threshold referenced in FAR 15-404-3©(1)(i). Does the prime contractor have to cause the subcontractor to submit certified cost or pricing data or can the prime simply submit the subcontract agreement and the initial prime analysis used to determine the reasonableness of the T&M rates?