The Department of Defense issued a final rule revising the DFARS “Proposal Adequacy Checklist” on January 29, 2014 to eliminate question 19 of that checklist which addresses whether the contractor cost proposal, to which the checklist applies, demonstrates that price analysis of costs for all proposed commercial items was performed. The DOD determined that questions 14 and 17 address price analysis for all proposed materials and subcontracts, commercial or otherwise, therefore making question 19 duplicative and unnecessary.
All contractors submitting a cost proposal to the DoD where cost or pricing data is required must complete, self-certify, and submit the DFARS proposal adequacy checklist with the proposal, as stipulated by the DFARS 252.215-7009 solicitation provision. The absence of the contractor completed and self-certified checklist can render the proposal unacceptable and non-responsive to the solicitation.
Not until DFARS was amended in March 2013 was there a requirement for contractors to formally attest to the adequacy of their cost proposals, and before the final rule implemented that provision, many observers considered the self-certification requirement of no added value since government auditors would nonetheless perform its own independent “adequacy” review of cost proposals.
After learning that question 19 was eliminated by the January 2014 rule, one client official noted that perhaps the next DFARS rule pertaining to the checklist would eliminate all other questions as being redundant as well.
Darryl Walker is a Emeritus Advisor for Government Compliance with Redstone Government Consulting, Inc., and formerly served as an Owner and Technical Director for the Beason & Nalley Government contract consulting group for over ten years. He provides content for our Government Insights Newsletter, provides training courses to government contractor and business community leaders, and consults with government contractors regarding a vast range of issues including cost proposals and presentations, internal controls, proposal preparation, compliance with the FAR and Cost Accounting Standards, litigation support, specialized claims, defective pricing issues, liaison with procurement and DCAA audit officials, and accounting and management systems compliance. Prior to joining Redstone Government Consulting, Darryl worked with the Defense Contract Audit Agency (DCAA) for almost 34 years in a variety of technical and management capacities. During his tenure with DCAA, Darryl provided audit services to a wide range of government agencies, including the Department of Defense, NASA, Department of Energy, Department of Interior, General Services Administration, and Department of Justice. During his experience with DCAA, Darryl audited over 3,000 government contractors throughout the Southeastern United States, Europe, and the Middle East. Education Darryl is a graduate of Texas Wesleyan College with a major in accounting and minor in economics.