In the scenario, none of the contractors (Prime, sub1, or Sub2) will have their portion of the change exceed the $700K threshold for CP data. But Far 15 dictates that since the overall proposal is over $700K, then the prime must submit C&P data. What C&P data will the prime have to submit? Since each of the sub's portion is $400K then aren't they exempted from submitting C&P data? If so, then what exactly will the Prime be submitting certified C&P data for? Will the Prime only submit C&P data for their $200K portion of the proposal? What will the Prime be required to submit in relation to the subs? If the certification submitted by the Prime is intended to cover the entire proposal, then what exactly is the Prime certifying in relation to the subs since the subs were not required to submit C&P data and certification? How can the prime issue a blanket certification for portions of the proposal that are covered by subs that do not exceed the $700K threshold? In summary, in this scenario what is required from the Prime and subs as far as the Cost and Pricing Data required for the modification proposal since the overall proposal is greater than $700K?
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It does not matter that the Sub does not break the Threshold. The entire modification is more than $700K. The prime is responsible for certifying the data, how he gets that from the SUBS is his business.
According to FAR 15.403-4 (b)(1) The certified cost or pricing data and data other than certified cost or pricing data required by the contracting officer to determine that the price is fair and reasonable. This is any all data that is pertinent to the modification in question and how they came up with those numbers.
This may also help you along. You can try to get a waiver according to FAR 15.403 (c) (4) Waivers. Your technical folks should have come up with an Independent Government Estimate, with this market research they should be able to determine a fair and reasonable price. This should be enough for your HCA to grant a waiver.