New TINA Threshold Implementation Considerations

The threshold requirement for submitting certified cost or pricing data raises from $750 thousand to $2 million in less than a month (July 1, 2018). See "Its Official - TINA Threshold for All Government Contracts Will Increase to $2 Million" for a fuller explanation.

What about modifications made to a prime contract that was entered into before July 1st? Those contracts will still have the $750 thousand threshold clause.

In the case of a change or modification made to a prime contract that was entered into before July 1, 2008, the threshold for obtaining certified cost or pricing data remains at $750 thousand.

What about subcontracts by prime contractors under a pre-July 1, 2018 contract awarded after July 1, 2018? In this case, an exception is available" but you've got to ask.

Upon the request of a contractor that was required to submit certified cost or pricing data in connection with a prime contract entered into before July 1, 2018, contracting officers can modify the contract to reflect a $2 million threshold for obtaining certified cost or pricing data for subcontracts entered into after July 1, 2018. 

Such modification won't cost a contractor anything. According to the regulations, contracting officers shall make all such modifications without requiring consideration.

If you're ready to award a subcontract between $750 thousand and $2 million requiring the submission of certified cost or pricing data, hold off for a month so all parties can benefit from the higher threshold. If you're a subcontractor on the cusp of receiving a subcontract between $750 thousand and $2 million requiring the submission of certified cost or pricing data, talk to the prime contractor about deferring award until after July 1, 2018.

More information is available here.