Skip to content

Menu

LexBlog, Inc. logo
NetworkSub-MenuBrowse by SubjectBrowse by PublisherJoin the NetworkGet StartedSubscribeSupportContact
Search
Close

DoD and NASA Propose New Rule for Uniform Line Item Identification Structure in Gov’t Contracts – Comment Period Ends October 6th

By Edward Goetz on August 11, 2014
Email this postTweet this postLike this postShare this post on LinkedIn

DoD, NASA, and the GSA have proposed a new rule that would change the federal acquisition regulation to establish a uniform line item structure for the Federal procurement system.  The rationale for the change is that a uniform line item identification structure would improve the accuracy, traceability, and usability of procurement data.  It is also part of the effort to implement the objectives of the Federal Funding Accountability and Transparency Act of 2006, including promoting achievement of rigorous accountability of procurement dollars and processes.

The new rule would apply to solicitations, government-wide acquisition contracts, multi-agency contracts, purchase orders, agreements involving pre-priced supplies or services, and delivery orders.  If approved, the change would become effective in FY 2016.

This is a significant change, as companies submitting cost-price proposals requiring certified cost or pricing data would need to show relationships between line or sub-line items and total contract price.  Further, they would have to attach cost-element breakdowns for each proposed line or sub-line.

The proposed rule could require some contractors to restructure their proposal pricing process as well as their systems to accommodate the line item identification system.  This change may also require contractors to make changes to their pricing and electronic systems and to develop more extensive pricing data to conform to a new line item structure.  Those who already have contracts with DoD would not be affected by the rule because these identification standards are already in use.

Crowell & Moring’s government contracts team is available to discuss the proposed rule and assist clients with submitting comments.

Photo of Edward Goetz Edward Goetz

Edward Goetz is the Director for International Trade Services in Crowell & Moring’s Washington, D.C. office. Edward leads the firm’s international trade analysts providing practice support to the International Trade Group in the areas of customs regulations, trade remedies, trade policy, export control…

Edward Goetz is the Director for International Trade Services in Crowell & Moring’s Washington, D.C. office. Edward leads the firm’s international trade analysts providing practice support to the International Trade Group in the areas of customs regulations, trade remedies, trade policy, export control, economic sanctions, anti-money laundering (AML), anti-corruption/anti-bribery, and antiboycott. He has extensive government experience providing information and interpretive guidance on the International Traffic in Arms Regulations (ITAR) concerning the export of defense articles, defense services, and related technical data. He also assists attorneys with matters involving the Export Administration Regulations (EAR), economic sanctions, AML, anti-corruption/anti-bribery, and trade remedies.

Read more about Edward GoetzEmail
Show more Show less
  • Posted in:
    Government Contracts
  • Blog:
    Government Contracts Legal Forum
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

Call us at 1-800-913-0988 or email sales@lexblog.com.

Facebook LinkedIn Twitter RSS
The Library at LexBlog
  • About LexBlog
  • The Field We Built
  • Library at LexBlog
  • Our Beliefs
  • Our Team
  • Contact LexBlog
  • Disclaimer
  • Editorial Policy
  • Terms of Service
  • Get Started
  • Publishing Solutions
  • Compass
  • Submit a Request
  • Support Center
  • System Status
Copyright © 2026, LexBlog, Inc. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo