ARTICLE · 14 JUNE 2018

DP/DPAP Guidance Increases Defective Pricing Risk For Contractors Certifying Current Cost/Pricing Data

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Dentons' Government Contracts team recently profiled the increased dollar threshold for certified cost and pricing data, and the actions the Defense Pricing/Defense Procurement and Acquisition Policy...

United StatesGovernment, Public Sector

Phillip Seckman

J. Quincy Stott

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Dentons' Government Contracts team recently profiled the increased dollar threshold for certified cost and pricing data, and the actions the Defense Pricing/Defense Procurement and Acquisition Policy (DP/DPAP) has taken to implement the increased threshold. This was welcome news, as it should ease the burden on contractors and reduce the number of negotiated contracts where certified cost and pricing data will be required.

The relief DP/DPAP gave with one hand, it appears to be taking away with the other. On June 7, 2018, DP/DPAP issued a memorandum ((Memorandum) directing new policy regarding cost or pricing data sweeps and certifications. Of particular note for contractors, the Memorandum instructs contracting officers to defer consideration of the impact of any cost or pricing data submitted by a contractor after price agreement is reached "until after award of the contract action in order to avoid delays." Cost or pricing data submitted after price agreement

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