Friday, October 11, 2013

Proposal Adequacy Checklist - Redux

Back in March of this year, DoD added a new DFARS Proposal Adequacy Checklist at DFARS (DoD FAR Supplement) 215.408(6). This change requires contractors to complete the Proposal Adequacy Checklist (DFARS checklist) and submit it with their proposals whenever the submission of certified cost or pricing data is required.

DCAA (Defense Contract Audit Agency) recently published a version of the checklist with different column headings. The DFARS checklist has two columns; "Proposal page No." and "If not provided EXPLAIN (may use continuation pages)". The DCAA checklist has "Adeqate Yes, No, or N/A" and "Comments". DCAA is calling theirs an optional version of the DFARS checklist with modified columns to assist auditors with documenting contractor compliance with the DFARS requirements for an adequate proposal.

Contractors should not use the DCAA checklist in lieu of the DFARS checklist. The DFARS checklist contains a reference to a specific proposal section or page number where the checklist adequacy item is contained or documented. The DCAA checklist does not include it. The DFARS checklist also requires an explanation when a checklist item is not satisfied. In most cases, the explanation will be because the cost element is not proposed. For example, checklist items 15, 16, and 17 are going to be N/A if there are no subcontracts proposed. The DCAA checklist does not solicit such information.

Note that this DFARS requirement does not automatically flow down to subcontractors but contractors would be wise to flow it down as part of their subcontract solicitation requirements. Its not a bad checklist and should help contractors and subcontractors to ensure the adequacy of their proposals.

We would appreciate feedback from anyone who has experience in completing this new checklist. Particularly, we are interested in how long it takes to complete it, problems in cross-referencing to a particular page in the proposal, and difficulties in understanding the questions.

DCAA's new checklist is available here.

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