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  • Question

    Do I need a SF1411 from the sub- supplier used in the supplier's proposal as the sub-supplier's proposal was over $750K for all the parts. Supplier said that probably the sub supplier final Po will be more about $300K .


    Answer

    1. The FAR and DFARS references quoted below in pertinent part are applicable to this response.

    FAR 52.215-12 -- Subcontractor Certified Cost or Pricing Data
    (a) Before awarding any subcontract expected to exceed the threshold for submission of certified cost or pricing data at FAR 15.403-4 [i.e.,$750,000] on the date of agreement on price or the date of award, whichever is later; or before pricing any subcontract modification involving a pricing adjustment expected to exceed the threshold for submission of certified cost or pricing data at FAR 15.403-4 [i.e.,$750,000], the Contractor shall require the subcontractor to submit certified cost or pricing data (actually or by specific identification in writing), in accordance with FAR 15.408, Table 15-2 … unless an exception under FAR 15.403-1 applies.

    FAR 52.215-13 -- Subcontractor Certified Cost or Pricing Data – Modifications
    (b) Before awarding any subcontract expected to exceed the threshold for submission of certified cost or pricing data at FAR 15.403-4 [i.e.,$750,000], on the date of agreement on price or the date of award, whichever is later; or before pricing any subcontract modification involving a pricing adjustment expected to exceed the threshold for submission of certified cost or pricing data at FAR 15.403-4[i.e.,$750,000], the Contractor shall require the subcontractor to submit certified cost or pricing data (actually or by specific identification in writing), in accordance with FAR 15.408, Table 15-2 … unless an exception under FAR 15.403-1 applies.

    DFARS 252.244-7001 -- Contractor Purchasing System Administration
    (b) General. The Contractor shall establish and maintain an acceptable purchasing system. Failure to maintain an acceptable purchasing system, as defined in this clause, may result in disapproval of the system by the Contracting Officer and/or withholding of payments.

    2. As indicated in the prime contract clauses FAR 52.215-12(a) and FAR 52.215-13(b), certified cost or pricing data is only required from a subcontractor (i.e., supplier in this case) if the value of the subcontract is expected to exceed $750,000. Therefore, because this inquiry stipulates that the final purchase order is expected to be $300,000, then certified cost or pricing data would not be required.

    3. As a result, an “SF1411” also would not be required in this case. However, please note that as indicated in the web link below, the form SF1411, “Contract Pricing Proposal Cover Sheet” had been cancelled as of 9/1997 with no replacement and is therefore obsolete. Consequently, unless the company’s approved purchasing system still requires the use of this form for subcontract transactions exceeding $750,000 when no exception applies, then this form would no longer be required under any circumstances.
    http://www.gsa.gov/portal/forms/download/115790 



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