Blog Tags - Noncompetitive price analysis

Government audit agencies and contract evaluation boards have voiced concern over the use of GSA Schedule rates as a basis of comparison for a FAR Part 15-type price analysis. There are several factors influencing this concern, including but not limited to the use of untracked and unverified costs in the build-up of GSA rates (TINA and CAS are not applicable to commercial item procurements and GSA Schedules are issued under FAR Part 12); and the inclusion of costs that are not ordinarily a factor in FAR Part 15 rates (like IFF).

The techniques in 15.404-1(b)(2) are set out in order of preference. 15.404-1(b)(3) introduces this concept and says that the techniques other than (b)(2)(i) and (ii) may be used as required by the circumstances surrounding the procurement if, and only if, (i) and (ii) aren't available. So you can look at this step-by-step narrative as compliance with FAR 15.404-1(b)(3) requirements.