Proposals for Government contracts that require “Cost and Pricing Data” can include thousands of pages and millions of lines of financial information.  And believe it or not, someone has to read all that data.

To simplify the task, the National Aeronautics and Space Administration, better known as NASA, last month published a new rule requiring offerors to use a specific form to index their cost and pricing data (79 Fed. Reg. 10687, February 26, 2014).  The form includes 34 questions that must be answered–either by indicating where in the proposal the relevant data may be found or explaining why that type of data is not required.  NASA says that no information is required in proposals that wasn’t already required; all that’s new is the standard format.

For now, this requirement applies only to NASA solicitations.  But, NASA may be on to something that all contractors can learn from.

The Government Accountability Office (GAO) has said many times that it’s the offeror’s responsibility to submit a proposal that responds to, and demonstrates a clear understanding of, the solicitation requirements; where a proposal fails to do so, the offeror runs the risk that the procuring agency will evaluate the proposal unfavorably.  Many disappointed offerors know the frustration of being told that their proposals were so poorly organized that evaluators couldn’t find or understand required or important information.  Good organization, indices, and tables of content take more work, but they could pay off with a better evaluation, whether on technical or cost realism.

So remember, providing the cost and pricing data may not be enough if the agency can’t find it.