# Class Deviation 2014-O0011
# Class Deviation 2014-O0011 - Determination of Fair and Reasonable Prices When Using Federal Supply Schedule Contracts

Status: Active
Scope: All DoD ordering activity contracting officers using Federal Supply Schedules

## Summary

This deviation replaces FAR 8.404(d) to clarify that ordering activity contracting officers bear responsibility for making fair and reasonable price determinations on individual orders, BPAs and orders under BPAs placed against Federal Supply Schedule contracts. While GSA determines that schedule prices are fair and reasonable for purposes of establishing the schedule contract, that determination does not satisfy the contracting officer's independent obligation. Contracting officers must apply the proposal analysis techniques at FAR 15.404-1, with the level of detail scaled to the complexity and circumstances of each acquisition.

## Required Contracting Officer Actions

1. Apply FAR 8.404(d) (Deviation) in lieu of the standard FAR 8.404(d) when placing orders, establishing BPAs or placing orders under BPAs against Federal Supply Schedule contracts.
2. Make an independent determination of fair and reasonable pricing for each individual order, BPA and order under a BPA using the proposal analysis techniques at FAR 15.404-1, calibrating the depth of analysis to the complexity and circumstances of the acquisition.

## Notes

GSA Determination Scope: GSA's fair-and-reasonable determination applies only for the purpose of establishing the schedule contract itself and does not substitute for the ordering activity contracting officer's own determination at the order level.

Effective Date and Duration: The deviation is effective immediately and remains in effect until incorporated into the DFARS or otherwise rescinded.

## Suggested Questions

You can ask your AI assistant:
- What actions do I need to take for this deviation?
- Does this deviation affect commercial acquisitions under Part 12?
- Which clauses need to be removed from my existing contracts?
- Are there any SAM registration implications?

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Source: https://part52.dev
Generated: 2026-03-20
Memorandum: https://www.acq.osd.mil/dpap/policy/policyvault/USA001004-14-DPAP.pdf