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    How does one determine if a single proposal containing FAR part 12 and FAR part 15 items exceeds the cost or pricing data threshold ? If the commercial items and non-commercial items are separated, they are both under the threshold. However, the total proposal dollar value is over the CPD threshold. Is there any FAR reference or other source that deals with this situation?


    One of the prohibitions for obtaining certified cost or pricing data at FAR 15.403-1 is for commercial items, and the way to comply with that prohibition for the commercial items (think commercial contract line items) is to back out the commercial CLINs from the determination. Once that is done, the non-commercial CLINs fall below the threshold and are thus exempt from the requirement to submit certified cost or pricing data.

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