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Found 8 results

  1. Federal Register :: Defense Federal Acquisition Regulation Supplement: Requiring Data Other Than Certified Cost or Pricing Data (DFARS Case 2020-D008)
  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 numbers provided. That's a bit of background. Now, the prime has requested CIJ for several parts. Some of these parts were ordered years ago and some have open orders currently. To my knowledge, it is the Prime's responsibility to have done the price/cost analysis and price comparison at all times. Our prime is insisting that we, the sub, must provide CIJs with fair & reasonable price analysis for the parts requested. Our senior leadership insists this is not the case. I have reached out the DCMA to ask on the issue and they seem to side with us that ultimately, that responsibility was and is still the Primes but also encouraged us to work with the Prime if the DCMA is requesting the information. Sorry if this is a long read, my question is: Is our company correct in our assertion that this is all the Prime's responsibility and we are not obligated to provide CIJ? Is there a certain point from the RFQ, to the quote, to the purchase order where our obligation to provide ends? Going further, do we even have a obligation when during the RFQ, quote phase to provide anything? I believe the sub most likely does not have an obligation since the Prime can just move on before awarding any sub a contract if they refuse to provide a CIJ. Thank you.If there is any confusion, please let me know and I will do my best to answer it.
  3. I'm trying to show where price analysis are required for the cumulative value of a contract vs the value of the contract action. I have always been taught that a price analysis needs to be completed for anything over $3500 for the cumulative value of the contract. However, I'm having a hard time finding that information in the FAR. For example my original award is $3,000 I purchase additional quantity for $1,000 Is a price analysis needed because the procurement is $4,000. If so where does FAR state that. Thank you in advance!
  4. This is a first: We have a client that has used redacted invoices for support of price analysis of a commercial item and the government customer sent the following response:"A recent DoD OIG inspection just slammed an agency for relying on sales data that did not include customer names. We need to see customer names to perform a valid analysis."I've requested this OIG report, but in the meantime, does anybody else have experience with this or have a copy of the OIG report that discusses this?
  5. We conduct cost/price analysis on behalf of federal primes and subs and have never flinched in using prior price history as a basis for price analysis (assuming, of course, that the historical price can be substantiated as fair and reasonable as well as a suitable basis in and of itself, a whole other topic of conversation...) Recently, we took a closer look at FAR 15.404-1( (2), which reads as follows: The Government may use various price analysis techniques and procedures to ensure a fair and reasonable price. Examples of such techniques include, but are not limited to, the following: (ii) Comparison of the proposed prices to historical prices paid, whether by the Government or other than the Government, for the same or similar items. This method may be used for commercial items including those “of a type” or requiring minor modifications. Am I reading this wrong or does this say analysis based on historical pricing is only valid for commercial items? Let's say the contractor purchases items which required cost analysis (subject to TINA). Three months later, a new requirement pops up (under TINA threshold but over simplified acquisition). Since these are not commercial items, would this prior procurement and cost analysis not be a suitable basis for determining price reasonableness (of course after adjusting for quantity and passage of time)?
  6. FAR 15.404-1( b )(3) states that "The first two techniques [price analysis] af FAR 15.404-1( b )(2) are the preferred techniques." But nowhere can I find the answer to WHY these are preferred. OK, the #1 Adequate price competiton is obvious, but what of #2 Comparison to historical prices paid? Why would that be preferred over any of the other methods such as competitively published price lists or market research? At first I thought maybe #2 was an attempt at streamlining the analysis process (a time saver) but when one has to evaluate the changes in market conditions and such, it can be more time consuming that searching the Internet for same or similar items or looking at a price list. Any ideas?
  7. Hi all, I've followed discussions of WIFCON for the past year but have never posted anything until now. I have a question concerning price evaluations on a Part 15 solicitation. The solicitation includes an IDIQ (labor rate schedule) and a first task order, both of which require pricing. The evaluation criteria sets out that the government will "evaluate the price through an evaluation of the proposed labor rate schedules, a price analysis and realism analysis of the first task order and a determination on cost reasonableness". So let me pose a "for instance". Let's say two offerors end up in source selection with essentially similar technical evaluations and similar IDIQ price schedules when all option years are considered. But one has a higher task order price then the other, although the task order price for each of these offers are determined to be both reasonable and realistic. In the absence of any further discussion of price evaluation in the solicitation than the above line, could 15.404-1( b ) price analysis of the first task order be used to give greater preference to the bid with the lower task order price? Thanks in advance!
  8. Many times we use a learning curve as we conduct price analysis to determine a price fair and reasonable. However, we are not allowed to conduct a learning curve using a previous buy that was determined fair and reasonable using price analysis via a learning curve. I can't seem to find any guidance regarding this policy. Can you please provide some references that support this policy or guidance as to why this is the rule.
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