Performing meaningful cost analysis at the MAC level presents challenges. Any sample task that could be provided would not encompass all the types of labor that could potentially be utilized at the task order level. The solicitation for the MAC IDIQs will set a contractual ceiling for both cost- and fixed price type CLINs. FY17 NDAA language provides relief from the cost evaluation when the government will award to all qualifying proposals, which would be the case here however the NDAA language is not yet captured in the FAR. I saw a previous answer from 2015 which looked to be a similar situation and the recommendation was to issue a basic agreement in lieu of a MAC. Is there any other possible solution?
This response is based on the information provided. We suggest you discuss with your contracting officer and/or legal department as appropriate.
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One thought is to pursue a deviation with DPAP in anticipation of FY17 NDAA implementation.
A more local approach would be to request a DCMA/DCAA validation of proposed rates to serve as your cost analysis given the nature of your acquisition.