TINA - Subcontractor Certification

(c) Any contractor or subcontractor that is required to submit certified cost or pricing data also shall obtain and analyze certified cost or pricing data before awarding any subcontract, purchase order, or modification expected to exceed the certified cost or pricing data threshold, unless an exception in 15.403-1(b) applies to that action.

Unless an exception in 15.403-1(b) applies, you are required to obtain and analyze certified cost or pricing data before award.

FAR 15.404-3(c)(1) reads:

1) The contractor shall submit, or cause to be submitted by the subcontractor(s), certified cost or pricing data to the Government for subcontracts that are the lower of either --

• (i) $12.5 million or more; or

• (ii) Both more than the pertinent certified cost or pricing data threshold and more than 10 percent of the prime contractor’s proposed price, unless the contracting officer believes such submission is unnecessary.

This section is giving threshold limits on, WHAT INFORMATION NEEDS TO BE SUBMITTED TO THE GOVERNMENT. If the subcontract falls below the thresholds, the process still happens, however, the data does not go all the way to the government.

FAR 15.404-3(b)(3), that section reads, (3) When required by paragraph (c) of this subsection, submit subcontractor certified cost or pricing data to the Government as part of its own certified cost or pricing data.

Under the threshold limitation, if the subcontract falls below both thresholds, then subcontractor certified cost or pricing data would not have to be submitted by the contractor to the government as part of it's own certified cost or pricing data.