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Certified Cost and Pricing Data - Modifications


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Is ?certified? cost and pricing data required when terms and conditions are bilaterally modified in a contract (i.e. delivery schedule, warranty) and adequate consideration has been received. It should be noted that ?cost and pricing data? was provided but not certified because it included many assertions of judgment vice fact.

Thank you.

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Guest Vern Edwards

Certified cost or pricing data are required whenever a negotiated acquisition is expected to exceed the dollar threshold in FAR 15.403-4(a)(1) and when none of the exceptions in FAR 15.403-1(B) apply.

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Certified cost or pricing data are required whenever a negotiated acquisition is expected to exceed the dollar threshold in FAR 15.403-4(a)(1) and when none of the exceptions in FAR 15.403-1(B) apply.

Thanks Vern. I would normally request certified cost and pricing data when I receive both price increases and price decreases that would collectively exceed the dollar threshold in FAR 15.403-4(a)(1) but in this case there is not a proposed increase or decrease in price. I understand that there is a "value" associated with the clause change (For example: the "value" of an extension in delivery schedule is a reduced risk of being late on delivery) but is the contractor required to assign a dollar amount to each of these term and condition changes in order for them the "certify" to the cost and pricing? And, if the information is based on assumptions and "what if" scenarios, is that considered "certifiable"?

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Guest Vern Edwards

No. The contractor need not assign a dollar value to such things.

If there is no price adjustment then there is no need for certified cost or pricing data.

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Thanks Vern. I would normally request certified cost and pricing data when I receive both price increases and price decreases that would collectively exceed the dollar threshold in FAR 15.403-4(a)(1) but in this case there is not a proposed increase or decrease in price. I understand that there is a "value" associated with the clause change (For example: the "value" of an extension in delivery schedule is a reduced risk of being late on delivery) but is the contractor required to assign a dollar amount to each of these term and condition changes in order for them the "certify" to the cost and pricing? And, if the information is based on assumptions and "what if" scenarios, is that considered "certifiable"?

That's what I thought! Thanks again.

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No. The contractor need not assign a dollar value to such things.

If there is no price adjustment then there is no need for certified cost or pricing data.

That is, of course, provided that the $0 price adjustment is not the net result of $400k of cost increases off set by $400k of cost decreases. The total of $800k in changed costs in absolute value busts the current ceiling and triggers the need for CC/P data.

Elsewhere in this string, of course, some of the contributors are showing our age. Since FAR was revised to no longer contemplate 'cost or pricing data' that is not certified per TINA. Data such as was described in the original question of the string is now called by the very awkward phrase "data other than certified cost or pricing data'. I forget, was that tongue twister a gift we received from FASA or FARA? I think it was FARA.

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Guest Vern Edwards

Worker-B:

You'd better take another look at FAR. It now defines (1) cost or pricing data, (2) certified cost or pricing data, and (3) data other than certified cost or pricing data, each of which is defined slightly differently than the others.

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Worker-B:

You'd better take another look at FAR. It now defines (1) cost or pricing data, (2) certified cost or pricing data, and (3) data other than certified cost or pricing data, each of which is defined slightly differently than the others.

Maestro - You are, as always, correct. To be sure there are 3 separate definitions, but they are not really different in the case of C/P data and CC/P data? Certified Cost or Pricing Data's 'definition' starts out by saying that it is Cost or Pricing Data (implicitly deferring to the C/P data definition to tell us what that is) - and then goes on to describe the fact that the C/P Data is backed by a cert. Exactly as the phrases' wordings indicate. As far as an operating CO is concerned they only collect and use Certified C/P Data and "Data other than ...". There is no 3rd choice for the CO to go to.

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