Purpose of FAR 15.403-1(a)

[snydra]

Why does FAR 15.403-1(a) state that "Certified cost or pricing data shall not be obtained for acquisitions at or below the simplified acquisition threshold" while FAR 15.403-4(a)(1) states that "the threshold for obtaining certified cost or pricing data is $700,000"? Acquisitions at or below the simplified acquisition threshold will not exceed $700,000. Am I incorrect in thinking that FAR 15.403-1(a) is unnecessary?

[Guest Vern Edwards]

Whether it's unnecessary is a matter of opinion. But see FAR 15.403-4(a)(2). The purpose of FAR 15.403-1(a) is to emphasize that the SAT is the absolute limit on requirements to submit certified cost or pricing data. in any case, repetition is common in the FAR.

[snydra]

Thanks Vern, I understand it now. That paragraph had been bothering me a lot lately. There is a new proposed DFARS change that is adding provision 252.215-70XX Requirements for Certified Cost or Pricing Data and Data Other Than Certified Cost or Pricing Data. In both the Basic and Alternate I, paragraph (e) states "The Offeror shall require all prospective subcontractors above the simplified acquisition threshold in FAR part 2 to adhere to the requirements of paragraph © of this provision when determining that the proposed prices from prospective lower-tier subcontractors are fair and reasonable" Paragraph © is "Requirements for certified cost or pricing data".

I submitted a comment to regulations.gov asking why this provision states all lower tier subs greater than SAT have to adhere to the requirements of certified cost or pricing data rather than all subs greater than the truthful cost or pricing data threshold. In light of your prior reply, I still think the proposed DFARS provision is in error, because it would be the call of the HCA to determine if certified cost or pricing data can be required, and the provision paragraph is talking specifically about subcontractors and their lower-tier subcontractors. What are your thoughts? Is there something I am missing?

The proposed change is located at http://www.regulations.gov/#!documentDetail;D=DARS_FRDOC_0001-0831 for reference.