SSGR Contracts

Great question! The most recent DCAA audit was issued in June 2017, and DCAA did not comment on the contractor's system description because (surprise) they didn't have one. We cited the contractor for not having an official system description and they submitted a draft to us last fall (final due this month). They do make distinctions between cost estimates in their SD. Their draft exempts ROMs and other budgetary documents that do not constitute a "proposal" in the narrow sense from the clause requirements because there is "no expectation that these estimates will directly result in contract award." Question for you, do you have a citation for your comment "all proposals covered by the contractor's estimating system"? The only reason I ask is because that gets to the heart of my original question (and you alluded to it as well). Does the contractor have the latitude to pick and choose which proposals must comply with the clause criteria? My assumption is that by default all of them do, otherwise there is no standard. Am I thinking this one through? The clause is invoked on the contract, and there are no alternatives or qualifiers, so my conclusion is they must comply. What would give them the freedom to exempt some proposals from the requirements? Thanks for all the input.

Yes. Another person in our department has cognizance over the purchasing system and they conduct the CPSR. I have cognizance over the EVMS and estimating system only.

Just to clarify, I work for SUPSHIP Groton and we are the ACO for this particular contractor. My primary job function is to perform surveillance of the contractor's estimating system per our NAVSEA instruction. We have a local DCAA that performed a full review of the estimating system and we made a final determination on the system last year. We're in the process of closing that audit. By surveillance I mean ensuring the contractor's system complies with the DFARS criteria. We accomplish this through proposal reviews, looking at policies and procedures, analyzing forward pricing rates, and a variety of other methods. Again I appreciate the input from everyone.

Jacques, not to nitpick or be argumentative, but the clause uses the word "proposal" in the definition of estimating system in section (a), and three other times at (d)(2)(i), (d)(4)(xv), and (d)(4)(xvi). Not only that, but would you agree that "cost estimates" are transferred to the Government via proposals? So in essence, the clause is speaking of proposals by using the explicit language of "proposals" and "cost estimates." In general, I appreciate the feedback from everyone. Perhaps I should've worded my question better. Granted my contractor meets the criteria in the prescriptions, during surveillance of their estimating system, do I only focus on those proposals that will require COPD? Is it fair for me to say that all of the proposals produced by their system must comply with the criteria set forth in (d)(4) of the clause?

I am being challenged about my interpretation of DFARS 252.215-7002 Cost Estimating System requirements. Wherever I read the word "proposal" in the clause, I'm interpreting it as any and all proposals provided by a contractor. It seems pretty black and white to me. My challenger thinks it only applies to proposals above the TINA threshold. What say you? Does DFARS 252.215-7002 apply to ALL proposals, or only those which require certified cost or pricing data? Any insight you can provide is greatly appreciated.