Regarding 52.215-22, in determining if "...the offereror intends to subcontract more than 70 perent of the total cost of work to be performed..." should bill of material items be used in the calculations?

Yes, if there was only a bill of material that would be the logical way to calculate the cost of work to be performed. If there was more than a bill of material, it would be reasonable to aggregate the bill of material with the cost of the other work to be performed. Am I missing something about your question?

InNeedofWisdom,

I think you understand my question. I was just thinking the question of whether or not value is added to materiel items is a little illogical. Materiel is bought in order for the prime to provide value added work. It seems to me that the real intent of the provision is to help the Government understand why it makes sense for large protions of work to be subcontracted (I guess the alternative would be to contract directly with that particular subcontractor).

Yes