DoD Announces Higher Certified Cost or Pricing Data Threshold

The Department of Defense has issued Class Deviation 2018-O0012, which raises the threshold for obtaining certified cost or pricing data to $2 million.

FAR 15.403-4 sets the threshold for obtaining CCPD at $750,000. However, section 811 of the National Defense Authorization Act for Fiscal Year 2018 (PL 115-91) increased the threshold for obtaining CCPD under the Truth in Negotiations Act (10 USC 2306a) and 41 USC 3502 from $750,000 to $2 million.

Since 41 USC 1502(B)(1)(B) equates the cost accounting standards threshold to the TINA threshold for obtaining CCPD, DoD has also increased the threshold for CAS applicability to $2 million.

The class deviation includes five deviated clauses/provisions and directs contracting officers to use them in lieu of FAR 52.230-1 through FAR 52.230-5:

  • 230-1 Cost Accounting Standards Notices and Certification (DEVIATION 2018-O0012)
  • 230-2 Cost Accounting Standards (DEVIATION 2018-O0012)
  • 230-3 Disclosure and Consistency of Cost Accounting Practices (DEVIATION 2018-O0012)
  • 230-4 Disclosure and Consistency of Cost Accounting Practices—Foreign Concerns (DEVIATION 2018-O0012)
  • 230-5 Cost Accounting Standards—Educational Institution (DEVIATION 2018-O0012)

The class deviation goes into effect on July 1, 2018. The text of the notice and the deviated provisions and clauses can be found here.