Proposal Adequacy Checklist—The New Normal Breakout Session # B01 Robert E. Jones, Advisor, Left Brain Professionals Inc. Suzanne Camden, Accounting Manager, Colonna's Shipyard Monday, July 28 2:30 PM – 3:45 PM What Is the Proposal Adequacy Checklist? • A consolidation of existing regulatory requirements to communicate adequate proposal expectations to contractors. 2 Why Do We Have It? • Systematic failure to submit may lead to estimating system deficiency report • The expected benefit is a reduced number of inadequate proposals, thereby making the acquisition process more efficient. 3 Who Administers the PAC? • Issued with RFP by CO – DoD/DFARS (36 items) – DCAA (points to DFARS) – DCMA (38 items) – NASA (34 items) 4 When Is It Required? • When certified cost or pricing data is required – The PAC addresses exemptions, so you may be required to submit the PAC even if you are exempt from submitting certified cost or pricing data 5 Will Other Agencies Adopt the PAC? • • DoD March 18, 2013 NASA February 26, 2014 6 Takeaway #1 • You have the exam in your hands! 7 What Does the PAC Look Like? 8 General Information • • • • • • Completed first page Need for GFE Non-compliance with CAS Activities that could materially impact costs Index Exceptions to submitting certified cost or pricing data 9 General Information • • • • Judgment factors Contingencies BoE relationships Subtotals that "cross and foot" and are indexed • FPRA 10 Cost Elements • Materials and Services • Subcontracts – Purchased Materials and Services • CBOM • Subcontractor proposals 11 Exceptions to Certified Cost or Pricing Data • Specifically identifed type of commercial item? • Classify modifications? • "Of a type" or "evolved" comparison provided? 12 Inter-organizational Transfers • Support for data submitted either at cost or price 13 Direct Labor • Time phased • Breakdown and summary by labor category • BoE with labor categories, hours, and task descriptions 14 Indirect Costs • Support for indirect rates 15 Other Costs • ODCs and basis of pricing • Royalties • Facilities capital cost of money 16 Formats for Submission Of Line Item Summaries • Are cost elements provided IAW FAR 15.408, Table 15-2 III • Are change order/mods IAW 15.408, Table 15-2.III.B • Are price revisions/redeterminations IAW FAR 15.408, Table 15- 2.III.C 17 FAR 15.408 Table 15-2 18 Other • Incentive - proposed target cost, target profit or fee, share ratio, etc. • EPA – rationale for adjustment • PBA IAW FAR 52.232-28 • Excessive pass-throughs identified 19 Differences Among PAC Versions • Variations in grouping and details, but content is essentially the same 20 How Many "No's" Are Allowed • No set criteria, though several "No's" could indicate an inadequate proposal 21 Takeaway #2 • Build internal policies and procedures 22 Frequently Asked Questions • What if I don't submit a checklist? If systematic, auditor could submit an estimating system deficiency report • Do I have to flow down to subcontractor? It depends, read the RFP to the sub 23 Takeaway #3 • Save time and simplify negotiations 24 Resources • DFARS Case 2011-D042 • http://goo.gl/6MYcmd • DCAA Memo on Proposal Adequacy Checklist • http://www.dcaa.mil/mmr/13-PSP-020.pdf 25 Resources • DCAA Contract Pricing Proposal Adequacy Checklist • http://www.acq.osd.mil/dpap/dars/dfars/html/cu rrent/252215.htm#252.215-7009 • DCMA Proposal Adequacy Checklist • http://guidebook.dcma.mil/120/DCMA_Propos al_Adequacy_Checklist.pdf 26 Resources • NASA Proposal Adequacy Checklist • http://www.hq.nasa.gov/office/procurement/reg s/5215-16.htm#52_215-77 27 3 Takeaways • You have the final exam in your hands! • Build internal policies and procedures • Save time and simplify negotiations 28 Questions Robert E. Jones robert@leftbrainpro.com (513) 728-1163 Suzanne Camden suzannecamden@hotmail.com (757) 572-1716 29 30