Tuesday, October 29, 2013

NASA Wants Its Own Proposal Adequacy Checklist

Today, NASA published a proposed rule in the Federal Register which would require contractors (and prospective contractors) to complete and submit a proposal adequacy checklist along with its proposal whenever certified cost or pricing data is required. The proposed checklist is very similar to the DoD checklist which became effective last March and which we have already written about. The proposed NASA checklist has two fewer checklist items than DoD's checklist.

The objective of NASA's proposed rule, like DoD's before it, is to ensure that offerors submit thorough, accurate, and complete proposals. It is expected that by completing the checklist, offerors will be able to self-validate the adequacy of their proposals which will improve the quality of their initial proposal submissions. This, in turn, will reduce the need for contractors to rework their initial proposal submissions which will save the Government time and resources in performing the evaluation of the proposal.

The NASA checklist adds the following to Checklist Item #3: "If your organization is subject to Cost Accounting Standards (CAS), does the proposal identify the current status of your CAS Disclosure Statement". Otherwise, Item #3 reads the same in both the DoD and NASA versions.

The NASA checklist omits Items #15 and #19 in DoD's checklist. Item #15 reads:
Has the offeror identified in the proposal those subcontractor proposals, for which the contracting officer has initiated or may need to request field pricing analysis (DFARS 215.404-3)?

Perhaps the omission is because the requirement references a DoD FAR Supplement requirement or because that particular DFARS makes no such requirement as we reported here.

The other DoD Checklist item not found in NASA's proposed checklist is Item #19 which reads:
Does the proposal include a price analysis for all commercial items offered that are not available to the general public (FAR 15.408, Table 15-2, Section II, Paragraph A)?
There is a 60 day comment period that ends on December 27, 2013 should you care to comment.

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