B01 - Proposal Adequacy Checklist—The New Normal

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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.
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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?
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•
DoD March 18, 2013
NASA February 26, 2014
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Takeaway #1
• You have the exam in your hands!
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What Does the PAC Look Like?
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General Information
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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
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General Information
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•
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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
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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
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Other Costs
• ODCs and basis of pricing
• Royalties
• Facilities capital cost of money
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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
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FAR 15.408 Table 15-2
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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
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Differences Among PAC Versions
• Variations in grouping and details, but
content is essentially the same
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How Many "No's" Are Allowed
• No set criteria, though several "No's" could
indicate an inadequate proposal
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Takeaway #2
• Build internal policies and procedures
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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
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Takeaway #3
• Save time and simplify negotiations
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Resources
• DFARS Case 2011-D042
• http://goo.gl/6MYcmd
• DCAA Memo on Proposal Adequacy
Checklist
• http://www.dcaa.mil/mmr/13-PSP-020.pdf
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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
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Resources
• NASA Proposal Adequacy Checklist
• http://www.hq.nasa.gov/office/procurement/reg
s/5215-16.htm#52_215-77
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3 Takeaways
• You have the final exam in your hands!
• Build internal policies and procedures
• Save time and simplify negotiations
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Questions
Robert E. Jones
robert@leftbrainpro.com
(513) 728-1163
Suzanne Camden
suzannecamden@hotmail.com
(757) 572-1716
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