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Found 6 results

  1. Representative Thornberry has introduced a discussion draft of his proposed FY19 acquisition reform efforts. In it he proposes to separate the definition of "commercial item" into "commercial product" and "commercial service." The following is the proposed definition of "commercial product" (emphasis added below): I'm curious to hear others' interpretations of the meaning of paragraph 4 (in bold above). Thanks in advance to anyone willing to share her/his thoughts.
  2. Hello again, We are currently subcontractors to a program and the prime has asked us for several commercial item determinations out of the blue. My company asserts commerciality of our parts on all quotes. They have always taken the stance that during valid period of the quote, and before a purchase order is placed, our company will provide any price analysis and assist in any commercial item justifications (CIJ). Should any price analysis or CIJ be provided, we do expect something in writing on the Prime's letterhead stating they accept our assertion of commerciality on the part n
  3. For a small woman owned business (OEM manufacturer), what is the true advantage for insisting on selling its product solely as commercial items? If selling as non-commercial items, CAS does not apply as company is a small business. Technical Data Rights clauses do apply but with careful planning, company's technical data can remain its own. It seems that most FAR and DFARS clauses of import would revolve around providing of certified cost and pricing data (FAR 52.215-10 thru 14) and (FAR 52.215-20 and 21), and Audit rights (FAR 52.215-2). It seems to me that the government and prim
  4. Here is a question: A subcontractor made a proposal to design, manufacture and sell widgets that did not include a commercial item assertion. Subcontractor was selected as a sole source for these products and has been selling these for a number of years. Can a subcontractor now assert commerciality for these parts? Thanks
  5. I found an interesting speech about HR 1670 from 1995 (which I do not believe was signed into law) at http://www.defense.gov/Speeches/Speech.aspx?SpeechID=948. Here are some quotes. I wonder if the speaker meant to include FASA from 1994 when he said "current acquisition reform proposals". Does his statement about HR 1670 apply today? Here was the speaker's perception about attitudes in 1995 when he (the deputy DoD inspector general) was delivering this speech. I wish the speaker had given more data to back up the following claim. Is that so? Here is part of the conclusion of the speech. W
  6. A few years ago, an official (Army? Corps of Engineers?) issued what I think was a policy letter explaining why construction is not a commercial item/service. Has that letter (that I can't find now) been superseded or rescinded by another letter or DFAR/FAR regulation? After many internet, DFAR, & FAR searches, I turn to you for help! Thanks!
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