Is the use of multiple 6298's allowed in AE contracts? Can the firm be instructed to tabulate the information and use averages to consolidate onto one form? If the Government only has a contractual relationship with the prime, then why would the 6298s from the subs be incorporated into the contract? I cannot find much info in FAR other than that it is requirement for contracts over 50k and discretionary for under 50k.
This response is based on the information provided. We suggest you discuss with your contracting team, program manager and/or legal department as appropriate.
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We searched the FAR. The form referenced does not exist in the FAR. With further research we found the form you appear to be referring to is a VA form, VA Form 10-6298. We found it in the VAAR at VAAR 836.606-71 Architect-engineer's proposal. This form is apparently for the collection of cost data regarding a contractor proposal. We would want the offeror to keep each subcontractor's cost data separate so we could get appropriate insight to individual subcontract costs. This allows for less manipulation of data by the prime in its submission. The firm correctly notes each subcontractor has different overhead rates, hourly rates, mileage, etc. and the VA does not want to lose its ability to see this at the more granular level.
Any decision to do other than as prescribed in VAAR 836.606-71 would require a VA determination at the appropriate review/approval threshold.