Data to support proposal analysis
Contracting officers must obtain and properly document sufficient data—through field pricing and audit assistance as needed—to ensure fair and reasonable pricing in government contracts.
Overview
FAR 15.404-2 outlines the requirements and procedures for obtaining and using data to support proposal analysis in government contracting. It details when and how contracting officers should request field pricing and audit assistance, the types of information that may be sought, and the proper handling and reporting of such data. The regulation also addresses the responsibilities of contracting officers, auditors, and administrative contracting officers (ACOs) in ensuring that proposal data is sufficient, accurate, and appropriately protected. It provides guidance on dealing with deficient proposals and the steps to take if access to necessary data is denied.
Key Rules
- Field Pricing Assistance
- Contracting officers should request field pricing assistance when available information is inadequate, tailoring requests to the minimum essential data needed for analysis. Field pricing can include technical, audit, and market information.
- Reporting Field Pricing Information
- Results of field pricing reviews can be reported orally, in writing, or electronically, and must be included in the official contract file. Written reports should be shared with relevant parties, including audit agencies.
- Audit Assistance
- Contracting officers should contact the cognizant audit office directly for audit support, and should not request redundant preaward audits unless prior audits are inadequate. Auditors control the scope of audits and have exclusive access to financial records.
- Deficient Proposals
- If proposal data is insufficient or access is denied, the contracting officer must act promptly to obtain the required data, and may withhold award or refer the matter to higher authority if issues persist.
Responsibilities
- Contracting Officers: Request and tailor field pricing/audit assistance, ensure proper reporting and file documentation, act on deficient proposals, and protect proprietary information.
- Contractors: Provide timely and adequate data, grant access to records, and cooperate with audits and reviews.
- Agencies/Auditors: Conduct reviews/audits, report findings, and notify contracting officers of deficiencies or significant new information.
Practical Implications
- Ensures fair and reasonable pricing through thorough proposal analysis.
- Promotes collaboration between contracting officers and field experts.
- Protects sensitive information and maintains audit integrity.
- Non-compliance can delay awards or result in escalation to higher authorities.