FAR 15.404-1(b) identifies various price analysis techniques and states that the first two techniques cited are preferred. Therefore, the subcontract administrator should follow this preferential order when analyzing price by addressing each FAR 15.404-1(b) technique from an applicability perspective before settling on the technique to be performed in the instant analysis. That is, the recommendation is not to merely skip to the price analysis technique that fits the situation best; rather, first explain in the price analysis why each technique was not employed. For example, if the “comparison of the proposed price to historical prices paid” price analysis technique will be used, first explain why “comparison of proposed prices received in response to the solicitation” was not available (e.g., non-competitive procurement).
(4) Debarment
A contractor’s reliance on the Excluded Parties List System (or System for Award Management – “Exclusions”) for debarment verification of a subcontractor is not acceptable from a DCMA standpoint. Instead, DCMA interprets FAR 52.204-6 to require written debarment certification of a subcontractor on the day-of-award for purchases (for other than commercially available off-the-shelf items) if the subcontract or order value is expected to exceed $30,000.00.
(5) Determination of Commerciality
DCMA is increasingly questioning “Commercial Item” FAR 2.101(6) (e.g., “catalog price” or “market prices”) commerciality determinations made by contractors. The catalog/market price is a high standard to legitimately substantiate in commerciality determinations for many professional/technical service procurements. Further, DCMA does not consider a GSA schedule as evidence of the availability of the “catalog price” in the commercial marketplace.
It is important to remember the DCMA CPSR Team has ever-changing federal regulation interpretations and resultant expectations (really requirements) when reviewing your purchasing system. This “moving target” reality is an ongoing compliance challenge for all contractors, including those with a currently approved system. No two CPSR analysts are the same, and neither are their interpretations and applications of the federal regulations.
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