Make-or-Buy Plans Earn Routine OMB Renewal
Published Date: 3/13/2025
Notice
Summary
The Department of Defense, GSA, and NASA want to keep collecting info from contractors about their make-or-buy plans when bidding on government projects. This helps the government understand what parts contractors will make themselves or buy from others. If you’re a contractor, get ready to keep sharing this info, and send any comments by April 14, 2025—no extra costs, just a smooth process extension!
Analyzed Economic Effects
7 provisions identified: 0 benefits, 7 costs, 0 mixed.
Report subcontract costs and pass-through details over 70%
FAR 52.215-22 and 52.215-23 require proposers to provide the total cost of work by the offeror and each subcontractor, and, if an offeror (or a subcontractor) intends to subcontract more than 70 percent of total cost, to disclose the indirect costs and profit/fee applicable and describe the value added by the offeror (or subcontractor). If subcontract effort later exceeds 70 percent of total cost, contractors must describe the value added by the reporting entity.
You must submit make-or-buy plans
If you bid on negotiated government contracts, you must submit a make-or-buy program under FAR 15.407-2(e). Your proposal must include items such as a description of each major item or work effort; categorization as “must make,” “must buy,” or “can either make or buy;” a proposed make-or-buy decision for items listed as “can either make or buy;” reasons for categorizations; plant or division designation; identification of proposed subcontractors and locations; any recommendations to defer decisions; and any other information the contracting officer requires.
Provide authorized negotiators' contact info
Under FAR 52.215-1(c)(2)(iv), firms offering supplies or services in negotiated solicitations must provide the names, titles, telephone and facsimile numbers, and electronic addresses (if available) of authorized negotiators. Contracting officers use this contact information during contract negotiations and it becomes part of the official contract file.
Must get approval for make-or-buy changes
FAR 52.215-9 requires contractors to submit, in writing, a notification and justification for any proposed change to the make-or-buy program that is part of the contract and to obtain the contracting officer’s advance approval. Contracting officers use this to ensure negotiated prices and performance remain satisfactory.
Identify items you won’t make or add value to
FAR 52.215-14 (Integrity of Unit Prices) requires offerors and contractors to identify, when requested or when there is inadequate price competition, supplies they will not manufacture or to which they will not contribute significant value. Contracting officers use this information to check whether cost allocations have distorted an item’s intrinsic value.
Notify government of ownership changes
FAR 52.215-19 requires contractors to notify the administrative contracting officer when they become aware that an ownership change has occurred, or is certain to occur, that could change the valuation of capitalized assets. This notification lets the Government apply cost principles for asset valuations after business combinations.
Continuation of information collection and time burden
The agencies are seeking to extend this existing information collection (OMB Control No. 9000-0048) and ask contractors to continue providing the listed FAR Part 15 information. The notice reports 122,097 respondents, 139,074 total annual responses, and a total annual burden of 43,027 hours (43,022 reporting hours + 5 recordkeeping hours); comments are due by April 14, 2025.
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Key Dates
Department and Agencies
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Previous / Next Documents
Previous: 2025-03996, Information Collection; Value Engineering Requirements
The Department of Defense, GSA, and NASA want to keep collecting info about value engineering, which helps save money and improve projects. They’re asking the public to share thoughts on this info collection by May 12, 2025. If approved, this will continue for three more years with no new costs or big changes.
Next: 2025-03998, Submission for OMB Review; North Carolina Sales Tax Certification
Contractors working on construction or vessel repairs in North Carolina need to keep proving how much they spent and paid in sales tax. The government is asking to keep this paperwork rule going to help get tax refunds for building materials. If you’re involved, get ready to keep those certified statements coming, and don’t miss the April 14, 2025 comment deadline!