Establishing Commercial Item Status
Q. We are a small, Department of Defense contractor and sell various defense products. Among other items, we provide compounds to several customers. In some cases, our compounds are our own, and in others, the formulation is made by various contractors, including ourselves. We often have contracts over the TINA threshold and we would like to create a price list that could be used to substantiate our compound prices, rather than have to justify the components of each compound every time we submit a quote. Will you please tell me how we might go about doing that?
A. You have a few ways to go on this. Yes, a price list will help establish your items are commercial items which will allow you to charge the government at those prices. Remember the closer the price list is to a catalog price list (think Sears) as opposed to an internal price list the easier it is to establish the items are commercial items. You may also want to provide documentation of the items being sold to non-federal customers to further establish your commercial item status. Alternatively (or in addition), you may want to establish a General Services Administration (GSA) price schedule that will then be used by most federal, state and local agencies. Once you have a GSA Federal Supply Schedule in place you can use those prices.
