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|General Discussion: FAR 15.403-4 Threshold Evaluation
Moderator: Tawny Kern, Views: 192Posted: 07-23-2012 02:01 PM
|Is a DoD prime contractor obligated to consider the combined value of all purchase orders issued to a prospective subcontractor in determining whether the threshold for obtaining the necessary cost or pricing data & sufficient documentation from its subcontractors under FAR 15.403-4? FAR 15.408, table 15-2 states that the offerer is required to obtain cost or pricing data from its prospective sources for those acquisitions exceeding the threshold set forth in FAR 15.403-4 & not otherwise exempt but does not address whether purchased parts under separate purchase orders need be combined in evaluating the threshold. Alternately, can individual purchased parts on multiple purchase orders to the same vendor on the same procurement be subject to a separate threshold for each purchase order? Or must all purchases (multiple purchase orders) to the same vendor be added together in the determination of whether the Prime must obtain and submit cost or pricing data from that vendor on the subject procurement. Scenario---The prime contractor proposes to purchase direct material parts (under a separate purchase order for each part) from the same vendor/subcontractor. The contractor's position is they are not obligated to combine the dollar value of the individual purchased parts under multiple purchase orders in evaluating whether the threshold for providing cost and/or pricing data is met for that vendor. The prime contractor indicates they do this because there may be revisions to individual part specifications by the procurement command. The current threshold is $700k.|
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