U.S. Department of Defense Class Deviation – Section 890 Pilot Program to Accelerate Contracting and Pricing Processes

Tom Reynolds


On January 19, 2023,U.S. Department of Defense (DoD) released Class Deviation 2023-O0004 – Section 890 Pilot Program to Accelerate Contracting and Pricing Processes. The January 19th class deviation rescinds a prior class deviation issued in 2020, with the objective of extending a pilot program authorized by Section 890 of the NDAA for FY 2019. The pilot program allows a Contracting Officer to determine the extent and structure of historical actual cost detail that a contractor can provide in lieu of certified cost or pricing data. Specifically, Section 890 authorized DoD to perform a pilot program for contract actions that exceed $50 million. Contracting Officers must request approval to participate in the pilot program, which was determined to be best suited to recurring contracts where there is reliable actual cost data maintained in approved contractor business systems.

The January 19th class deviation emphasizes the importance of communication between the contractor and the Contracting Officer. From a timing perspective, this class deviation will remain in effect until January 2, 2024 (unless otherwise rescinded).

The January 19th class deviation can be found here.

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