My company is working on a federal Request for Proposal (RFP) for IT services, NAICS 541519, due in three weeks. It's a full and open competition, not a set-aside. The solicitation package includes a reference to 'certified cost or pricing data' being required. We've done federal work before, but mostly smaller firm fixed price (FFP) contracts under the simplified acquisition threshold (SAT), which never asked for this. Our proposal consultant mentioned it’s a big deal. When exactly is this data required for a federal proposal, and what does it entail?
When is 'certified cost or pricing data' required for a federal proposal?
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Certified cost or pricing data is generally required for federal proposals when a contract action is expected to exceed the Truth in Negotiations Act (TINA) threshold, which is currently $2 million, unless an exception applies (FAR 15.403-4). Your proposal consultant is correct that it is a significant requirement. For state and local procurements, the requirement for cost or pricing data depends on the specific state or local procurement code and the guidance provided in the solicitation or vendor portal.
This data entails all facts that a prudent buyer would reasonably expect to affect price negotiations significantly, such as vendor quotes, nonrecurring costs, changes in production methods, and management decisions. You provide this data on a Certificate of Current Cost or Pricing Data, which attests that the data submitted is accurate, complete, and current as of the date of agreement on price. This requirement usually applies to negotiated procurements like your current RFP when the price is not established through adequate price competition, or when a commercial item exception does not apply. Since your current RFP is for IT services and not a set-aside, it is likely a substantial procurement that triggers this requirement.