DCAA guidance clarifies cost or price analysis requirements for subcontractor proposals

The Defense Contract Audit Agency (DCAA) published a Memorandum for Regional Directors (MRD) last week that provides answers to frequently asked auditor questions regarding cost and price analyses to establish the reasonableness of proposed subcontract prices. Of particular note is the direction that DCAA auditors proceed with subcontract proposal audits even if contractor cost or price analyses are not yet available. Dentons’ Government Contracts team explains what the new guidance means for contractors and subcontractors.

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About Steven Masiello

Steven M. Masiello is the chair of the US Government Contracts practice and a leader of the firm's Global Government Contracts and Procurement group. Masiello serves as lead counsel in complex government contract matters across numerous industry segments concerning state, federal, and foreign military funded transactions in the US courts, agency boards and under domestic and international alternative dispute resolution procedures.

About Thomas Lemmer

Thomas A. Lemmer routinely counsels and litigates for clients on US federal contract formation, contract administration and dispute resolution. Tom also counsels clients on global procurement issues, with the assistance of Dentons’ offices worldwide, including employment issues, how to do business in a given country, how to do business with the US government and risk assessments.