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    In a proposal is each part number handled as a stand alone to the FAR requirement? What if there are multiply part numbers on the proposal that are known to be awarded to the same supplier and awarded at the same time? Can you cum these part numbers to see if the threshold is met? What is the definition of a procurement? My current challenge is a contractor who generates many purchase orders, with one part number on each purchase order, to the same supplier, in the same week, saying that each part number's extended value is under $700k thus no certified cost and pricing data is required. If you add up two or three of these purchase orders it easily breaks the threshold.


    As shown at FAR 15.403-4(a)(1)(i), the requirement to obtain certified cost or pricing data is based on the value of a contract award...not on individual orders under a contract. If each supplier part constitutes a separate purchase order using FAR Part 13 procedures, then each "contract" is under $150,000 and thus does not meet the threshold for requiring certified cost or pricing data.

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