Delivering an Adequate Consolidated Bill of Materials in Your Proposal

Synopsis
When submitting a proposal in response to a Government solicitation, and assuming the contemplated acquisition is not otherwise exempt from requiring certified cost or pricing data per Federal Acquisition Regulation (FAR) 15.403, Obtaining Certified Cost or Pricing Data, an adequate Consolidated Bill of Materials (CBOM) is required for estimating proposed materials and services. The CBOM is a consolidated priced summary of individual material quantities included in the tasks or contract line items (CLINs) being proposed and provides the basis for pricing (vendor quotes, invoice prices, etc.).

Issue
Why is a CBOM important? It provides certainty to the Government that the prices proposed for materials and services are fair and reasonable at a consolidated level.

For example, a proposal contains two separate CLINs and Part Number 12345ABC is a required item for both CLINs. However, the part description for CLIN 0001 is “Red Widget” and for CLIN 0002 “Blue Widget” despite the fact that both descriptions refer to the same item. This can result in unnecessary duplicative efforts in evaluating both the “Red Widget” and “Blue Widget” if the descriptions are not uniform and if the quantities in the individual CLIN bills of material are not subsequently combined in the CBOM for the entire proposal. In addition, this can distort the quantities actually needed for the entire acquisition and any potential pricing discounts from bulk quantity buys can be lost.

An adequate CBOM is an essential tool in determining a fair and reasonable price for proposed materials and services. The CBOM serves to:

  • aggregate quantities to determine if there are bulk quantity discounts that can result in cost savings to the Government
  • eliminate duplicate efforts to evaluate the aggregate quantity requirements for the entire acquisition
  • determine pricing reasonableness if the same material item is used in multiple proposed tasks, orders, or CLINs
  • ensure proposal uniformity and consistency

Proposed materials, services, and subcontracts generally comprise a large portion of proposals. Therefore, they receive significant scrutiny from the Contracting Officer (CO) and/or the Contracting Officer’s Representative (COR) in determining a fair and reasonable price for the acquisition.

When evaluating an offeror’s proposal, one of the first steps taken by the CO/COR is to review the proposal for adequacy by following an adequacy checklist such as the Defense FAR Supplement (DFARS) proposal adequacy checklist found in DFARS Clause 252.215-7009. One of the many requirements in the checklist is a CBOM as specified in FAR 15.408 Table 15-2 Section II.A, which must:

“Provide a consolidated priced summary of individual material quantities included in the various tasks, orders, or contract line items being proposed and the basis for pricing (vendor quotes, invoice prices, etc.). Include raw materials, parts, components, assemblies, and services to be produced or performed by others. For all items proposed, identify the item and show the source, quantity, and price… These requirements also apply to all subcontractors if required to submit certified cost or pricing data”.

In the Government contract acquisition industry, proposals are often determined to be deficient because of an inadequate CBOM. This can occur whether the offeror is a smaller, inexperienced, non-major subcontractor or a multi-billion dollar, major Government contractor with a history of Government contracting experience. An inadequate CBOM may result from simple oversight, lack of training, lack of awareness of FAR solicitation requirements, misinterpretation of FAR requirements, turnover in staff, or a combination of these and other factors.

A proposal may be returned to the offeror at the discretion of the CO for revision to address and inadequacies. The determination of an inadequate proposal due to an inadequate CBOM is one of many potential proposal deficiencies that can be cited by the CO. Adverse consequences may include inviting further scrutiny of the adequacy of other cost elements in the proposal, unsupported costs, cost concerns, and questions about the offeror’s internal controls over the estimating process that can result in an estimating system deficiency.

What does CohnReznick Think?
CohnReznick can help Government contractors prepare adequate CBOMs that can improve Government review of the contractor’s proposals. We can assist Government contractors in submitting complete, reasonable, and realistic cost proposals that can win competitive procurements. Our practice professionals have served as both as Government employees and as third-party auditors contracted directly by Federal Government agencies.

Here are several of our resources that may help you:

  • CohnReznick Insights (cohnreznick.com/insights): Provides CohnReznick’s latest insights on business trends, regulatory developments, and economic issues. You can subscribe to receive Insights e-newsletters by email.
  • CohnReznick Website (cohnreznick.com): In addition to Insights, our website provides extensive information about all aspects of Accounting and Assurance, Tax, and Advisory services.
  • CohnReznick GovCon360 (govcon360.com): Keeps you up-to-date on the ever-changing regulatory environment that is government contracting. From reference materials to educational presentations and thought leadership pieces on industry matters, GovCon360 is a valuable resource for the Government contracting professional.

Contact
For more information, please contact Tony Liao, Senior Associate (tony.liao@cohnreznick.com or 703.744.6723) or Kristen Soles, Partner (kristen.soles@cohnreznick.com or 703.847.4411).

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