New Opportunities, New Risks—New Cost or Pricing Data Thresholds

The National Defense Authorization Act for Fiscal Year 2018 amended the Truth in Negotiation Act’s (TINA) cost or pricing data report threshold, effective July 1, 2018 for all Department of Defense (DoD) procurement contracts, if no exceptions apply.  Assuming that the requirements are put into regulation in the near term, the TINA amendment raises the threshold for submitting certified cost or pricing data (i.e., that the data are current, accurate and complete) from contracts valued at $750,000 or more to contracts that are valued at $2 million or more.