Sep 29 2011
Comments Filed on the Draft Commercial Item Handbook Revision 2 (09/29/2011)
Posted in: IDCC Papers
On November 29, 2011, in response to the Federal Register Notice of 9/29/2011, requesting comments on the Commercial item Handbook version 2, the IDCC filed comments. The IDCC had provided comments in 2009, on a previous revision, which were given fair consideration. The comments filed in November addressed a couple of syntax error issues, plus concerns with a couple of other sections of the newest revision. Specifically, comments were provided on the Subcontract Commercial Item Determination section requesting that the FAR Council delete portions of text that were contrary to (D)FAR 15.403.1 b3. Comments were also suggested regarding the section limiting the “sources to establish price reasonableness.” It was proffered that price reasonableness can also come from government sales, such as sales under a GSA schedule. Finally, a new proposed Appendix to the Commercial Item Handbook was submitted. This new Appendix is a list of”Lessons Learned,” which is designed to aid in the acquisition process between the government or prime contractors and subcontractors.
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