In review of the FAR, it is assumed the requirement under 2.32 is based on 48 CFR 52.215-23 Limitations on Through Charges. Under 48 CFR 15.408 – Solicitation provisions and contract clauses, the limitation on Pass Charges clause is incorporated into contracts where both the total estimated contract exceeds simplified acquisition threshold and the expected contract type is a cost reimbursement type contract. As this is to be a Firm Fixed Price contract there does not appear to be a need for this clause. Please clarify the basis for this additional clause. Exhibit 3. Cost Accounting Standards The purpose for including the Cost Accounting Standards (CAS) Exhibit was Notices and Certification. to obtain information on the Offeror’s Disclosure Statement and an assigned Administrative Contracting Officer (ACO). The subsequent subcontract will Under Exhibit 3 WRPS has requested be a significant award and a clear understanding of the Offeror’s business “Offerors shall examine each part and systems and status are being reviewed. The Exhibit will need to address at a provide the requested information in minimum: order to determine Cost Accounting Standards (CAS) requirements applicable 1. Statement if your company has submitted a CAS Disclosure Statement. to any resultant contract.” 2. Provide the status of the CAS Disclosure Statement (e.g. date of the compliance determination). The proposal team in coordination with 3. Provide Offeror’s point of contact for the CAS Disclosure Statement. our accounting department has examined 4. Provide the contact information for the Offeror’s cognizant Administrative the exhibit along with the Firm Fixed Price Contracting Officer (ACO). contract type proposed under Solicitation No: 307550. Specific clauses we believe WRPS understands that the award may not be subject to CAS based on the are pertinent to the discussion are listed evaluation criteria being based on competition and the contract type being below. Through our examination we Firm Fixed Price (FFP). believe this contract is exempt from CAS due to 48 CFR 9903.201-1 (b) (15) which
In review of the FAR, it is assumed the requirement under 2.32 is based on 48 CFR 52.215-23 Limitations on Charges. Under 48 CFR 15.408 – Solicitation provisions and contract clauses, the limitation on Pass Through Charges clause is incorporated into contracts where both the total estimated contract exceeds simplified acquisition threshold and the expected contract type is a cost reimbursement type contract. As this is to be a Firm Fixed Price contract there does not appear to be a need for this clause. Please clarify the basis for this additional clause. Exhibit 3. Cost Accounting Standards Notices and Certification. Under Exhibit 3 WRPS has requested “Offerors shall examine each part and provide the requested information in order to determine Cost Accounting Standards (CAS) requirements applicable to any resultant contract.” The proposal team in coordination with our accounting department has examined the exhibit along with the Firm Fixed Price contract type proposed under Solicitation No: 307550. Specific clauses we believe are pertinent to the discussion are listed below. Through our examination we believe this contract is exempt from CAS due to 48 CFR 9903.201-1 (b) (15) which The purpose for including the Cost Accounting Standards (CAS) Exhibit was to obtain information on the Offeror’s Disclosure Statement and an assigned Administrative Contracting Officer (ACO). The subsequent subcontract will be a significant award and a clear understanding of the Offeror’s business systems and status are being reviewed. The Exhibit will need to address at a minimum: 1. Statement if your company has submitted a CAS Disclosure Statement. 2. Provide the status of the CAS Disclosure Statement (e.g. date of the compliance determination). 3. Provide Offeror’s point of contact for the CAS Disclosure Statement. 4. Provide the contact information for the Offeror’s cognizant Administrative Contracting Officer (ACO). WRPS understands that the award may not be subject to CAS based on the evaluation criteria being based on competition and the contract type being Firm Fixed Price (FFP).
307550_Qquestions_and_Answers_020820171.docx