RGCI - DCMA Commercial Item Group - Year in Review

What is the Commercial Item Group (CIG)?

So, what is the DCMA CIG? They are the “cadre of experts” established under DCMA as a result of Section 831 of the FY 2013 National Defense Authorization Act (NDAA). The purpose of the CIG is to assist DoD contracting officers in making commercial item determinations. There are several DCMA ACO’s that have warrants specific to making commercial item determinations on contractor assertions or higher-tier contractor determinations of its supplier’s assertions at the request of a buying command. DCMA CIG has price analysts and engineers that perform market research, evaluate the commercial submission, determine whether pricing is fair and reasonable as well as provide negotiation support.

FY 2021 Accomplishments for the CIG

DCMA Commercial Item Group (CIG) issued their FY 2021 Year in Review whereby the DCMA CIG Contracting Officers determined 87% of the products they reviewed to be commercial items which involved over 2,000 unique part numbers. The CIG also supported Contracting Officers in pricing of COVID 19 vaccines and therapeutics.

The DCMA CIG prepared white papers and held webcasts with DAU on pricing Other Transactions (OT), Software, and Intellectual Property (IP). The white paper links are on the DCMA website under “Additional Resources” and the links to the webcasts with CIG, Defense Acquisition University, and other government agencies discussing the three topics are included next to each of the topics below.

  • OT Pricing Paper – White paper on leveraging pricing techniques to support the determination of a fair and reasonable pricing OTA efforts.
  • Software Pricing – White paper on the list of elements, approaches, and considerations to include when evaluating software pricing.
  • Draft IP Pricing Paper – Draft Intellectual Property paper on researching valuation analysis and pricing techniques.

We recommend that contractors review these whitepapers as they may provide useful insight into the information and techniques the government uses in evaluating pricing for OTA’s, software, or intellectual property.

Speed Up the Process but Do Not Give Contractors Full Access to the CIDs in the Database

The FY 2016 NDAA under 10 U.S.C 2380 mandated DoD to establish a centralized database and provide public access to DoD Contracting Officer commercial item determinations. The 2017 NDAA amended 10 U.S.C 2380 to reverse the public access and mandate DoD establish a centralized database to provide only officials of the DoD access to previous DoD commercial item determinations.

The purpose of the public facing database in the FY 2016 NDAA was to expedite the procurement process by allowing contractors and the government to have access to Contracting Officer (CO) Commercial Item Determinations and rely on them in subsequent procurements. A public facing database accessible to contractors would significantly reduce duplicate effort by contractors in performing market research and making commercial item determinations when an existing CO determination exists.

So, What Database is Available to the Contractor?

The DCMA CIG website contains a section titled “Commercial Item Database” with two Icons:

  • CIG Determination Repository (DoD & Public Access)
  • Commercial Item Database (DoD Access Only)

The first Icon, CIG Determination Repository is public facing but only has a searchable feature for a commercial item determination of parts where DCMA CIG Contracting Officers have reviewed and issued a commercial/noncommercial determination. Contractors can search by part number or description, and it will provide results of either Commercial, Noncommercial or no match. DCMA’s repository does not allow contractors to download the CID nor is DCMA’s repository complete as it does not include Procurement Contracting Officer Determinations.

The second Icon, Commercial Item Database (DoD access only). When you click on the Icon, it pulls up the Procurement Integrated Enterprise Environment (PIEE) website. The Commercial Item Database within PIEE contains Procurement Contracting Officer CIDs that are only accessible to DoD government officials.

CIG Virtual Office Hours

On the first Thursday of each month, DCMA CIG and DAU representatives host Virtual Office Hours where there is open dialogue to discuss solutions to challenges on commercial acquisitions. Anyone can call into the Office Hours. This is your chance to join in the conversation if you have any questions.

Utilize the DCMA CIGs Website for Pricing Techniques and CIDs

Pricing OT’s and software and valuing Intellectual property can be a complicated process. Contractors should consider reviewing the information in the whitepapers and webcasts when pricing these types of efforts. We also recommend contractors search the DCMA Commercial Item Repository for a prime or subcontract product or description of a product/service, before preparing a CID. If the search results indicate “commercial,” take a screen shot of the DCMA database to show the existence of a CID, include it in your proposal and move on to pricing. This will save you time in the proposal process as preparing a CID can involve extensive market research and completion of forms/documentation.

Redstone GCI is available to assist contractors in preparing commercial item assertions and making commercial item determinations. This includes describing the item and its functionality, performing market research for similar items, selection of the appropriate definition, and data to help support your proposed price.

Written by Lynne Nalley, CPA

Lynne Nalley, CPA Lynne is a Director with Redstone Government Consulting, Inc. providing government contract consulting services to our clients primarily related to Commercial Item Determinations and support, Cost Accounting Standards, DFARS Business System Audits, Proposals, and Incurred Cost. Prior to joining Redstone Government Consulting, Lynne served in several capacities with DCAA and DCMA for over 35 years. Professional Experience Lynne began her career working with DCAA in the Honeywell Resident Office, Clearwater, FL in 1984. Lynne’s experience included various positions which involved conducting or reviewing forward proposals or rate audits, financial capability audits, progress payments, accounting and estimating systems, cost accounting standards, claims and disclosure statement reviews. She is an expert in FAR, DFARS, CAS and testified as an expert witness. Lynne assisted in drafting the commercial item guidance for DCAA Headquarters. Lynne was assigned as a Regional Technical Specialist where she provided guidance to 20 field offices on highly complex or technical issues relative to forward pricing, financial capability or progress payment issues. As an Assistant for Quality, she was involved in reviewing and ensuring audit reports were in compliance with policy and GAGAS as well as made NASBA certified presentations to the staff including but not limited to billing reviews, CAS, unallowable cost and progress payments. To enhance her experience in government contracting, Lynne accepted a position with DCMA in 2015 as part of the newly organized DCMA Cadre of Experts in the Commercial Item Group. This included performing reviews of prime contractor’s assertions and/or commercial item determinations as well as performing price analyses. Lynne was a project lead and later became a lead analyst where she engaged with the buying commands on requests and reviewed price analysis reviews performed by a team of 5 analysts. She also assisted the DCMA CPSR team relative to commercial items and co-instructed the Commercial Item Training presented to DCMA. Education Lynne earned a Bachelor of Science Degree in Accounting from the University of Central Florida. Certifications State of Florida Certified Public Accountant State of Alabama Certified Public Accountant Defense Acquisition Workforce Improvement Act (DAWIA) Level III- Auditing DAWIA Level III – Contracting

About Redstone GCI

Redstone GCI is a consulting firm focused on fulfilling the needs of government contractors in all areas of compliance. With a singular mission to help contractors through the multiple layers of “red tape,” we allow contractors to focus on what they do best – support their mission with the U.S. Government. We are home to a group of consultants made up of GovCon industry professionals, CPAs, attorneys, and retired government audit and acquisition professionals.

Our focus and knowledge of audit and compliance functions administered by DCAA and DCMA will always be at the heart of what we do. However, for the past decade, we’ve strategically grown to support other areas of the government contractor back-office with that same level of focus and expertise. We’ve added expertise in contracts management, subcontract administration, proposal pricing, various software systems, HR and employment law, property administration, manufacturing, data analytics/reporting, Grant specialists, M&A, and many other areas. When we see a trend in the needs of contractors, we act to ensure we can provide the best expertise in the market to fulfill those needs.

One thing our clients can be certain of is that with the Redstone GCI Team in your corner, there is no problem too big and no issue too technical for our team to tackle.

Topics: Proposal Cost Volume Development & Pricing, Commercial Item Determination