b.  Estimating System

The following comments were submitted concerning estimating systems:

Comment: The respondent indicated that it is unreasonable for an acceptable estimating system to include controls for the contractor to compare projected results to actual results and analyze the differences. This is a major change in policy concerning fixed-price contracts and will open the door to wholesale Government access to contractor costs during fixed-price contract performance.

Response: This interim rule sets forth specific criteria for maintaining an acceptable estimating system. It is not unreasonable for a contractor to establish and maintain an acceptable estimating system that would include controls for the contractor to compare projected results to actual results and analyze any differences. Such controls provide a valuable metric for demonstrating the accuracy of estimates produced by the system. Systems that consistently produce accurate estimates with a reasonable degree of confidence can significantly reduce the number of Government resources required to review cost and price proposals. Accurate estimates also provide substantial advantages to the contractor by allowing a more accurate forecast of the projected rate of return. This existing requirement was relocated from 215.407-5-70 to the clause at 252.215-7002, Cost Estimating System Requirements.