Blog Tags - Competition

There are plenty of aspects of effective supply chain management within a CPSR environment that are difficult - specialty metals compliance, noncompetitive price analyses for prototypes, etc. But there are many compliance requirements that are downright simple. So simple, in fact, that many contractors talk themselves right out of easy answers and into more difficult situations than are necessary. Here are three VERY common examples:

I've been getting this question from clients a lot lately when I do Price Analysis training. The logic moves like this: ten subs are added to the team on a single or sole source basis (usually follow-on justifications). Since they were added on a noncompetitive basis, the logic goes, documenting price competition is a waste of time because you (the contractor) won't get competitive credit anyway from DCMA during a CPSR since both you and the sub "know" they're getting the work.

The farther a procurement strays from the Three Big C's of government procurements - Competition, Commercial Items and Constrictive Contract Types - the more documentation is required for a compliant file, the more public laws apply and the more opportunity for the file to create findings.  

One of the easiest mistakes to make when preparing for a CPSR is the implementation of "best practice" policies that are much stricter that FAR requirements (do your policies require you to obtain Reps and Certs rather than ORCA? Do your policies require source justifications for commercial item procurements under $150K?).

First things first - 15.404-1(b)(2) lists the seven (7) acceptable price analysis techniques for the evaluation of offeror proposals. The list is organized by order of preference, with the preferred technique (competition) listed first and the least reliable technique (other than cost and pricing days submitted by the offeror) listed last. When you dip below (b)(2)(i) or (ii), your price analysis narrative should succinctly explain why a higher analysis technique is not available. I'll provide some examples of how to do this down the road.