Beantown_Contracts Posted February 15, 2013 Report Share Posted February 15, 2013 Situation: A small business subcontractor is submitting a proposal in excess of $7.5m to a large DoD prime. The SB subcontractor will be asserting commerciality on this FFP proposal. Prime is demanding a DCAA compliant costing submission. (redacted to them, unredacted to the DoD customer) Given that the subcontractor is: a) a small business (CAS exempt) and submitting a Commercial (2.101), does the Prime or the DoD customer have the right to demand a DCAA compliant costing submission. Responses appreciated. B_C Link to comment Share on other sites More sharing options...
Don Mansfield Posted February 15, 2013 Report Share Posted February 15, 2013 What do you mean by "DCAA compliant costing submission"? Does that mean it has to be in the format of FAR Table 15-2? Link to comment Share on other sites More sharing options...
Beantown_Contracts Posted February 15, 2013 Author Report Share Posted February 15, 2013 Don, Thank you for the question. Customer is requesting labor rate build up. The Subk is not set up to provide accurate direct and indirect rates. The labor rates are on a published price list with substantial commercial type sales to affirm commerciality. V/R, B_C Link to comment Share on other sites More sharing options...
Retreadfed Posted February 15, 2013 Report Share Posted February 15, 2013 BC, look at MRD 11-PSP-017®, dated Sep. 29, 2011. This is the DCAA audit guidance on this point and can be found under the open audit guidance tab at the DCAA website. Link to comment Share on other sites More sharing options...
here_2_help Posted February 15, 2013 Report Share Posted February 15, 2013 BC, Just to add to what Retreadfed said, the requirement to supply cost or pricing data in FAR Table 15-2 format has nothing to do with CAS, and everything to do with FAR Part 15 requirements. If the company is asserting that its product meets the definition of a commercial item -- and can back that assertion up -- then it does not have to submit certified cost or pricing data. It may have to submit uncertified cost or pricing data, or information other than cost or pricing data. If it is not submitting certified cost or pricing data, then it does not have to follow the FAR Table 15-2 format. The company needs to help its prime establish price reasonableness, somehow. If it's not prepared to do that, then it shouldn't be in the government contracting business. At best, it should publish a product catalog and tell the prime contractor to submit an order via the company's internet ordering website. At worst, it should find another customer. On the other hand, I bet that's a big order for the small business. I wonder if the lure of big money is sufficient to force a cultural change? Hope this helps. Link to comment Share on other sites More sharing options...
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