Regarding the excerpt from the AFFARS below, it seems the guidance it provides is gray, for the use of the streamlined PNM for actions over the TINA threshold, but with exemptions. I have I have a $5M proposal of which $4.5M is commercial. Because of these parameters, I believe I can use a streamlined PNM. Is there documentation somewhere that spells out when I can and cannot use the Streamlined PNM process?
AFMC PGI 5315.406-3 Documenting the Negotiation
(a) For contract actions valued below the TINA threshold, the AF Streamlined PNM Format for supplies or services, or any other format which adequately addresses the basis of the proposed, objective, and negotiated amounts is available for use. If the value of the contract action exceeds the TINA threshold and no exception to TINA applies, it is expected that the pricing documentation will address the cost element composition of the proposed, objective, and negotiated positions at an appropriate level of detail based on the value and complexity of the pricing action.
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This was a great question! We reached out to the real experts for your situation. Below is the response we received from the policy experts at SAF/AQCP.
“A PCO needs to use discretion when documenting their negotiation based on the dollar value and complexity of the effort and there is no specific guidance to my knowledge that spells out when they can/cannot use the templates that are available since they are not mandatory use. Since they have an exception to TINA the language pertaining to expectations in documentation after the TINA threshold would not apply to this situation, however, I personally feel the Streamlined PNM templates don’t have enough guidance in them to properly document a deal over the TINA threshold that has a TINA exception. Ultimately a PCO need to make sure they have fully documented the effort and provided sufficient information to demonstrate the price is fair and reasonable. The PNM also assists those that have follow-on efforts and is a resource for things such as defective pricing situations, GAO/IG audits or internal inspections so preservation of relevant data/information is important.”
As an aside, there is an on-going Air Force the "PGI to TTP" initiative which might result in realignment or delete current Air Force PGI content. As they work towards the final dispositions on the PGI they might consider removing the links to the streamlining template until a chance to revise it or create another. “It is an older template that is in need of a refresh and there is some concern if the field would want to apply it on TINA exempt efforts over $2M.”