Cost and Pricing Data (Proprietary) Procedure

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Background

GovC's policy is to limit cost and pricing data to US Government channels, with exceptions. The exceptions are that the US Government is either unwilling to perform an audit of the subcontract, or doing so will delay the award of the subcontract. This procedure allows for the disclosure of cost and pricing data to upper level or prime contractors, providing certain requirements are met.

Scope and Applicability

This procedure is limited to solicitations to Prime Contractors or Upper Level Contracts where a cost based solicitation/procurement is being utilized and cost and pricing data is needed to verify that GovC's price is fair and reasonable.

Responsibility

Contracts is responsible for the administration of this procedure.

Procedure

GovC BUs are required to protect cost and pricing data through government channels. If going through government channels will not result in adequate review of fair and reasonable to upper level contractors in a timely manner, BUs may disclose cost and pricing data provided:

  1. The BU has submitted Forward Pricing Rate Proposals to the government 60 days prior to the upcoming fiscal year. Failure to do so requires approval from the CFO to not go through government channels for cost and pricing data audits.
  2. The BU has received a signed GovC Contractor Flowdown Certification.
  3. The BU has received a signed GovC Non-Disclosure Agreement.

When allowing an upper tier contractor to review and audit GovC's cost and pricing data, certain protocols must be maintained, such as:

  1. Any review must follow DCAA protocol of an entrance and exit conference.
  2. Details of the scope and materiality of areas audited must be disclosed by the auditor at the entrance conference.
  3. Details about any questioned or unsupported audit areas must be disclosed by the auditor during the audit and during the audit exit conference.
  4. The auditor must provide a time schedule and estimated level of effort to complete the review.
  5. The audit cannot exceed 5 days.
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