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    1. When must subcontractor cost or price analysis be included in the prime's proposal submission? For example, are primes only required to submit the cost or price analysis when the subcontractor's proposal exceeds the TINA threshold? (Reference: Proposal Adequacy Checklist #17) 2. "Subcontracts and services to be produced or performed by others" are identified as items that should be included in the Consolidated Bill of Materials (CBOM). (Reference: Proposal Adequacy Checklist #14) Does the FAR 44.101 definition of subcontractor apply to this checklist item? FAR 44.101 reads: "Subcontractor" means any supplier, distributor, vendor, or firm that furnishes supplies or services to or for a prime contractor or another subcontractor.


    Answer

    14. FAR 15.408, Table 15-2, Section II Paragraph A Does the proposal include a consolidated summary of individual material and services, frequently referred to as a Consolidated Bill of Material (CBOM), to include the basis for pricing? The offeror’s consolidated summary shall include raw materials, parts, components, assemblies, subcontracts and services to be produced or performed by others, identifying as a minimum the item, source, quantity, and price.
     
    16. FAR 15.404-3(c)

    FAR 52.244-2
    Per the thresholds of FAR 15.404-3(c), Subcontract Pricing Considerations, does the proposal include a copy of the applicable subcontractor’s certified cost or pricing data?
     
     
    17. FAR 15.408, Table 15-2, Note 1; Section II Paragraph A Is there a price/cost analysis establishing the reasonableness of each of the proposed subcontracts included with the proposal? If the offeror’s price/cost analyses are not provided with the proposal, does the proposal include a matrix identifying dates for receipt of subcontractor proposal, completion of fact finding for purposes of price/cost analysis, and submission of the price/cost analysis?
     
    Your first question asks “When must subcontractor cost or price analysis be included in the prime’s proposal submission.  The general answer is if the subcontractor’s proposal is either $12.5 M or more OR the proposal is above the TINA threshold and is 10% or more of the prime’s total proposal price.  But sometimes there are reasons why the Government contracting officer will request to see the analysis of a subcontractors proposal as described in FAR 15.404-3 (c) (2).  Typically the contractor officer will be asking for  “data other than certified cost or pricing data”.  If your questioning why you have to submit data, you should be able to get that answer from the Gov’t contracting officer.  Please read below the see the full details. 
     
    FAR 15.404-3(c) Any contractor or subcontractor that is required to submit certified cost or pricing data also shall obtain and analyze certified cost or pricing data before awarding any subcontract, purchase order, or modification expected to exceed the certified cost or pricing data threshold, unless an exception in
    15.403-1(b) applies to that action.
    (1) The contractor shall submit, or cause to be submitted by the subcontractor(s), certified cost or pricing data to the Government for subcontracts that are the lower of either --
    (i) $12.5 million or more; or
    (ii) Both more than the pertinent certified cost or pricing data threshold and more than 10 percent of the prime contractor’s proposed price, unless the contracting officer believes such submission is unnecessary.
    (2) The contracting officer should require the contractor or subcontractor to submit to the Government (or cause submission of) subcontractor certified cost or pricing data below the thresholds in paragraph (c)(1) of this subsection and data other than certified cost or pricing data that the contracting officer considers necessary for adequately pricing the prime contract.
    (3) Subcontractor certified cost or pricing data shall be submitted in the format provided in Table 15-2 of 15.408 or the alternate format specified in the solicitation.
    (4) Subcontractor certified cost or pricing data shall be current, accurate, and complete as of the date of price agreement, or, if applicable, an earlier date agreed upon by the parties and specified on the contractor’s Certificate of Current Cost or Pricing Data. The contractor shall update subcontractor’s data, as appropriate, during source selection and negotiations.
    (5) If there is more than one prospective subcontractor for any given work, the contractor need only submit to the Government certified cost or pricing data for the prospective subcontractor most likely to receive the award.

    Your second question
    asks “Does the FAR 44.101 definition of subcontractor apply to this  checklist item?  “Subcontractor” means any supplier, distributor, vendor, or firm that furnishes supplies or services to or for a prime contractor or another subcontractor. 

    Yes, you should use this definition.  I personally think it is unfortunate that “subcontractor” is not defined in FAR Part 2 definitions.  Sometimes subcontractor is used in the FAR to only mean the first tier subcontractor.  But most of the time, the definition comes from FAR 44.101.  The intention of the checklist is to get pricing information at all levels, thus the FAR 44.101 definition applies.
     

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