Jump to content
The Wifcon Forums and Blogs
Sign in to follow this  
FAR Fetched

Price Analysis for new Subcontractor

Recommended Posts

We have a prime contract vehicle with a Government customer. We're bringing on another subcontractor - the subcontractor is using their GSA Schedule rates. Do we still need to submit Price Analysis if they're using their GSA rates?

Share this post


Link to post
Share on other sites
We have a prime contract vehicle with a Government customer. We're bringing on another subcontractor - the subcontractor is using their GSA Schedule rates. Do we still need to submit Price Analysis if they're using their GSA rates?

Share this post


Link to post
Share on other sites
What is the value of the subcontract?

About 100k. I see the FAR mentions a 650k threshold, I'm just not sure how that applies when it's a new task on an existing contract.

Share this post


Link to post
Share on other sites
About 100k. I see the FAR mentions a 650k threshold, I'm just not sure how that applies when it's a new task on an existing contract.

My understanding (2 cents)--

For prime contract modifications, new subcontracts at any tier, and subcontract modifications, the applicable cost or pricing data threshold is established by the prime contract.

If the prime exceeds the 650k threshold and no other exceptions apply, I believe the analysis will be required. In particular,

"The award of a subcontract at any tier, if the contractor and each higher-tier subcontractor were required to submit cost or pricing data (but see waivers at 15.403-1©(4)). "

seems to require it if the prime required it--again, unless a waiver or exception apply.

Share this post


Link to post
Share on other sites

Submit "price analysis" to whom? At $100K you are talking about ?price? justification, not the submission and/or analysis of ?Cost or Pricing Data?.

At $100K a valid GSA Schedule should be sufficient for price analysis of "Fair and Reasonable", but I'm not to sure where it would fit into any "competition" requirement. The GSA price is supposedly a good price, but it is not guaranteed to be the lowest price.

Share this post


Link to post
Share on other sites

GSA pricing is considered to be competitive, so no price analysis is needed (see below excerpt from GSA website at http://www.gsa.gov/Portal/gsa/ep/contentVi...contentId=8106).

Ordering From Schedules

Orders placed against GSA Multiple Award Schedule (MAS) contracts, using the procedures in Federal Acquisition Regulation (FAR) 8.4, are considered to be issued using full and open competition (see FAR 6.102(d)(3)). ?[O]rdering activities are not required to make a separate determination of fair and reasonable pricing, except for the price evaluation required by FAR 8.405-2(d) when ordering services requiring a statement of work. By placing an order against a GSA Schedule contract using the procedures in this section, the ordering activity has concluded that the order represents the best value and results in the lowest overall cost alternative to meet the government's needs.

Share this post


Link to post
Share on other sites

wiscco,

The question was whether the prime is required to analyze the subcontractor's price. The rule that you are quoting deals with whether a Government ordering activity has to analyze a GSA schedule price. Two different things.

Share this post


Link to post
Share on other sites

Deleted - wrong thread.

Share this post


Link to post
Share on other sites
Guest
This topic is now closed to further replies.
Sign in to follow this  

×
×
  • Create New...