Can the Cost Realism Analysis be performed WITHOUT offeror's accounting system adequocy? In case of obtaining other than certified cost or pricing data?
In regard to adequacy, FAR 16.104 (i) states, "Before agreeing on a contract type other than firm-fixed-price, the contracting officer shall ensure that the contractor's accounting system will permit timely development of all necessary cost data in the form required by the proposed contract type."
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With respect to cost realism, FAR 15.404-1(d)(2) states, “Cost realism analyses shall be performed on cost reimbursement contracts" and FAR 15.404-1(d)(3) states, “Cost realism analyses may also be used on competitive fixed-price incentive contracts or, in exceptional cases, on other competitive fixed-price-type contracts”.
Consequently, but for an exceptional case, the determination of contractor accounting system adequacy is not an issue in cost realism applications since adequacy is already an underlying requirement of the type of contract on which cost realism is being performed.