Making a List and Checking It Twice: New Rule Requires "Adequacy Checklist" with Forward Pricing Rate Proposals

On December 11, 2014, DoD issued a final rule to instruct COs to request that contractors submit a Forward Pricing Rate Proposal "Adequacy Checklist" when submitting their FPRP. Under the rule, both the FPRP and the Adequacy Checklist are due at least 90 days before the proposed effective date of the rates, and DoD cautioned that "the proposed rates are based on forecasts and contractors must provide updates whenever the validity of the agreement may be affected."