Understand when a failure in a construction estimate may constitute gross error, when it is correctable, and how LINDB, TCU, materiality, and technical records guide the analysis.
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Gross error in construction estimates is not just any mistake, discrepancy, or imperfection in a spreadsheet. Under LINDB and Decree No. 9,830/2019, personal liability of a public official requires intent or gross error, understood as a manifest, evident, and inexcusable error committed with gross negligence, characterized by a high degree of negligence, recklessness, or lack of technical skill. The size of the loss, by itself, does not transform a failure into gross error, and the mere causal link between a decision and a bad result is also insufficient.
In the procurement process, however, two planes that are often confused need to be separated. One is the liability standard applicable to the official who prepared, reviewed, or approved a deficient estimate. The other is correction of errors in bidders’ proposals. A composition with an incorrect wage floor, a rounding issue, or another formal defect may be corrected through due diligence when the correction does not increase the proposal price, without this having any direct relationship with classification of a public official’s conduct as gross negligence.
The correct approach is to assess materiality, functional duty, information available, complexity, possibility of correction, expected diligence, and impact on competition, price, and execution. The estimate needs to be technically defensible; it does not need to be infallible.
What gross error means under LINDB
Liability for gross error depends on the context of the decision, the documentation, and the controls existing in the process. For an integrated view of this control framework, see What the TCU Reviews in Construction and Engineering Services Procurement.
Article 28 of the Law of Introduction to Brazilian Law establishes that a public official is personally liable for decisions or technical opinions in cases of intent or gross error.
Decree No. 9,830/2019 regulates this logic. Article 12 defines gross error as a manifest, evident, and inexcusable error committed with gross negligence and characterized by action or omission involving a high degree of negligence, recklessness, or lack of technical skill.
The definition is intentionally restrictive. It seeks to prevent every administrative decision that later produces an unsatisfactory result from automatically being converted into personal liability.
The decree also establishes important safeguards:
- intent or gross error must be proven in the liability proceeding;
- a mere causal link between conduct and damage does not imply liability;
- the complexity of the matter and the official’s duties must be considered;
- the amount of the damage, even if significant, does not by itself characterize gross error;
- a decision-maker relying on a technical opinion does not automatically assume the technical adviser’s liability;
- the rule does not dispense with diligent and efficient conduct.
Therefore, “it went wrong” and “there was gross error” are legally different conclusions.
An estimate containing an error does not mean the official acted irresponsibly
Every estimate is built using the information available on a given date.
Market prices change. Designs mature. Quantities may be refined. Field conditions may reveal variability. Quotations have dispersion. Reference systems work with assumptions and median values.
The existence of a difference between the estimated amount and the amount actually contracted or executed does not by itself prove a serious failure by the estimator.
Control needs to reconstruct the decision-making process:
- what information existed when the estimate was prepared;
- which sources were consulted;
- which level of design was available;
- which quantities could reasonably be known;
- which uncertainties were recorded;
- which method was adopted;
- whether a technical warning was ignored;
- whether an obvious lower-risk alternative existed;
- whether the team had adequate competence and reasonable time;
- whether the error was detectable through ordinary review.
This reconstruction is the opposite of judging the decision only with information acquired afterward.
Gross error by an official and a correctable proposal error are different concepts
The term “error” appears at different stages of procurement, and that creates confusion.
| Situation | Main question | Applicable rule |
| Poorly prepared base estimate | Was there gross negligence by the official? | LINDB Article 28 and Decree 9,830/2019 |
| Proposal with a formal defect | Can the proposal be corrected? | Law 14,133, due diligence, moderate formalism, and case law |
| Incorrect quantity | Does the design/estimate have technical support? | Planning, design, and calculation memorandum |
| Discrepant unit price | Does the reference represent the market? | Article 23, reference systems, and price research |
| Arithmetic error | Does correction alter substance or total price? | Correctability analysis |
| Loss to the public treasury | Who caused it, and with what degree of fault? | Individualized liability assessment |
A bidder may make a correctable error in a cost composition without that amounting to gross error. Likewise, the Public Administration may correct an estimate failure before bidding without the existence of the correction implying personal liability.
TCU Decision 2,009/2025 and moderate formalism
TCU Decision 2,009/2025-Plenary examined a proposal containing a professional wage below the minimum established in a collective bargaining agreement or labor decision.
The TCU considered the failure correctable: the bidder could submit a new corrected unit-cost composition, provided this did not increase the total proposal price.
The decision is important because it shows that evaluation is not intended to eliminate an advantageous proposal for every formal mistake.
The decision itself recalls examples of failures that do not automatically require disqualification, such as certain rounding violations or improper inclusion of taxes in a composition, where the proposal can be corrected without an improper substantive change.
This does not authorize “fixing the price” after the competition. The limit of correction is preserving the substance of the proposal, equal treatment, and the advantage originally offered.
Correctable does not mean irrelevant
A failure may be correctable and still deserve recording and control.
If a proposal uses a wage below the applicable floor, the Public Administration needs to verify whether the correction:
- maintains the total price;
- does not artificially shift cost to another component;
- preserves the corresponding charges and benefits;
- does not create unfeasibility in another component;
- remains compliant with the tender rules.
Correction requires technical analysis, not merely replacing a number.
The article on Fees in Engineering Consulting shows why labor references need a source, base date, comparable role, and coherent burden structure.
When the estimated budget may characterize gross error
TCU case law includes situations in which a deficiency goes beyond the normal margin of technical error and reaches a high degree of negligence or lack of technical skill.
Deficient market research combined with poorly sized quantities
In Decision 3,569/2023 of the TCU Second Chamber, the Court stated that gross error may be characterized when an estimated budget is prepared without adequate sizing of quantities and is based exclusively on research with potential suppliers, without considering similar procurements by the Public Administration, when this leads to substantial overpricing.
The problem was not merely choosing an imperfect source. It was the combination of basic failures in elements the responsible official had a duty to structure.
The decision produces a practical rule: price and quantity need to be audited together. An apparently reasonable price multiplied by an unjustified quantity still produces a poor estimate.
Procurement without justification of quantities
TCU Decision 2,459/2021-Plenary recognizes that preparing procurement documents without justifying quantities may be classified as gross error for sanctioning purposes.
The quantity memorandum is not a bureaucratic appendix. It explains why the Public Administration intends to purchase a given quantity.
In construction, this means maintaining a link among:
- drawings;
- technical memoranda;
- quantity takeoff;
- measurement criteria;
- estimate worksheet.
When a number appears without a source, control loses the ability to reproduce the estimate.
Approving tender documents without a detailed estimate and price justification
TCU Decision 2,121/2024-Plenary addressed the liability of a legal adviser who approved draft tender documents that lacked a detailed estimate and price justification. The TCU held that, in that case, the failure could constitute gross error because it did not involve a legal controversy or technical complexity capable of making the omission excusable.
The decision does not mean a legal adviser must recalculate an engineering estimate. The point is that certain essential elements of the process can be objectively checked for existence.
There is a difference between assessing the technical content of a composition and verifying that the record does not even contain the required detailed estimate or price justification.
Adopting an obviously uneconomic solution or methodology
The TCU Cost Engineering Guide includes, among examples of gross error in this area, situations in which design choices or estimating methodologies are clearly uneconomic and lack adequate technical justification.
Control needs to be cautious here. Engineering admits alternatives. A more expensive solution may be correct because of service life, risk, operations, safety, schedule, or performance.
The problem arises when an obviously less efficient alternative is adopted without study, comparison, or basis, despite the difference being known or easily demonstrable.
Ignoring obvious evidence of overpricing
If the ABC Curve shows a highly material item priced well above available references and no one investigates the discrepancy, the omission may become material.
The analysis of the five effects that distort SINAPI and SICRO is useful precisely because it shows that divergence from the reference may occur upward or downward. The error is not in diverging; it is in failing to investigate and document a material divergence.
Five elements that increase the risk of characterization as gross error
Based on legislation and case law, some elements make conduct harder to justify.
The duty was clear
The more basic and objective the obligation, the less room there is to claim reasonable doubt.
Examples include justifying quantities, maintaining a calculation memorandum, consulting the applicable reference, or verifying whether the record contains a detailed estimate.
The information was available
It is not reasonable to demand information that did not exist. It is different to ignore an official database, a quotation received, a design alert, or an existing technical opinion.
The impact was material
A small difference in an immaterial item has a different profile from a failure in an item representing a dominant portion of the estimate.
The ABC Curve helps demonstrate materiality.
The failure was detectable through ordinary diligence
An error hidden in highly complex modeling does not have the same nature as incorrect multiplication, incompatible units, a quantity without source, or complete absence of justification.
The decision has no supporting memorandum
Even a technically plausible choice becomes fragile when there is no record of the assumptions, comparison, and reasoning.
Documentation does not turn a bad decision into a correct one, but it makes it possible to demonstrate the reasoning that existed when the choice was made.
What should not automatically be called gross error
The regulation itself prevents automatic conclusions.
High amount of damage
Article 12, paragraph 5, of Decree No. 9,830/2019 establishes that the amount of damage, even if significant, cannot by itself characterize gross error or intent.
A multibillion-real project can turn a small percentage variation into an enormous absolute amount. The number does not replace analysis of the conduct.
Outcome different from the forecast
An estimate is an approximation. If an input suffers a market shock after the base date, the later difference does not prove that the original estimate was negligent.
Choice among defensible technical alternatives
Designers and estimators frequently choose among legitimate methods. Control needs to consider the information available, standards, performance, and risks.
Technically complex or disputed issue
The decree requires consideration of the complexity of the matter and the official’s duties. The more uncertain the issue, the more important it is to demonstrate that the professional assessed alternatives and supported the choice.
Error corrected in a timely manner
Identifying an inconsistency during review and correcting it before it produces effects is evidence that control is functioning, not a systemic failure that should be hidden.
The maturity of a process is not measured by absolute absence of error, but by its ability to detect errors before they become improper procurements or payments.
Rounding, formatting, and small inconsistencies require proportionality
Large spreadsheets contain thousands of cells, links, and operations. Small rounding or presentation differences may occur.
Treatment should consider:
- absolute value;
- percentage impact;
- position on the ABC Curve;
- effect on total price;
- possibility of objective correction;
- whether the substance of the proposal changes;
- existence of systematic behavior.
One cent per unit in a low-quantity item is different from systematically applying rounding to conceal millions of reais.
The relevant concept is materiality.
Absence of a detailed composition may have different degrees of severity
Not every documentary absence has the same consequence.
If the composition exists and was merely not attached because of a formal failure, the Public Administration may assess the possibility of correction before publication or within the applicable due-diligence rules.
If the estimate was formed without a composition, without a memorandum, and without any way to demonstrate the origin of the cost, the deficiency is substantive.
The question is whether the missing documentation was merely not filed or whether the technical work was never performed.
This distinction is essential in auditing.
Gross error cannot be analyzed only with the benefit of hindsight
After a construction project is completed, it is easy to know which quantities varied, which supplier won, which productivity was achieved, and where amendments arose.
The official who prepared the estimate did not have all of this information.
A fair analysis needs to reconstruct the state of knowledge on the decision date.
This involves:
- reviewing the design version current at the time;
- price databases available;
- quotations received;
- market conditions;
- meeting records;
- existing technical opinions;
- known warnings;
- time available for the decision;
- formal authority of each participant.
Judging with future data creates hindsight bias and may punish a reasonable decision merely because the result was unfavorable.
The calculation memorandum is the estimate’s main technical defense
A good memorandum is not produced to “defend the manager” afterward. It exists to make the estimate reproducible from the outset.
Depending on the scope, the memorandum should explain:
- source of quantities;
- measurement criteria;
- compositions used;
- adaptations to reference systems;
- quotations;
- statistical treatment;
- base date;
- location;
- productivity;
- losses;
- mobilization;
- burdens;
- BDI;
- contingencies;
- exceptional assumptions.
The Cost Engineering service exists precisely to turn an estimated price into a chain of technical evidence.
The ABC Curve helps demonstrate diligence proportional to materiality
No team has infinite resources to review every item with the same depth.
The ABC Curve can demonstrate that validation effort was directed toward items with the greatest economic impact.
A review policy may provide for:
- full review of Class A items;
- enhanced sampling in Class B;
- automated validations and sampling in Class C;
- mandatory investigation of outliers regardless of class;
- supplementary market research for critical inputs.
This does not create immunity. It creates a method.
If a BRL 20 million item receives the same attention as a BRL 200 item, the process is not using materiality rationally.
Price research: three suppliers are not a sufficient ritual
TCU Decision 3,569/2023 demonstrates the risk of basing an estimate exclusively on quotations from potential suppliers when other relevant references are available.
Robust research may combine:
- official systems;
- similar procurements;
- specialized media;
- broad-domain websites when appropriate;
- invoices and other admissible databases;
- justified direct quotations;
- updated internal history.
The number of sources does not replace the quality of the comparison.
Three suppliers may quote different specifications, quantities, or incompatible commercial conditions. Technical normalization is part of the research.
Quantity is as important as unit price
It is common to focus the audit on price and forget the multiplier.
Cost = Quantity × Unit Price
A quantity overestimated by 100% produces the same effect on the subtotal as a unit price that is twice as high.
For this reason, the estimate needs a quantity memorandum linked to the design.
Frequent errors include:
- measuring area where the service is paid by volume;
- counting equipment twice on different drawings;
- including reserve quantities without identifying them;
- applying waste to the quantity and again in the composition;
- using gross length without deducting interferences;
- replicating quantities from a previous design without validation.
When these failures affect material items and lack any justification, the risk of liability increases.
A worksheet “within SINAPI” can still be wrong
Using an official code does not automatically make the estimate correct.
Errors may occur when selecting:
- a composition technologically incompatible with the scope;
- the wrong unit;
- the wrong state or base date;
- a tax-relieved composition when a non-relieved composition should apply;
- a service with a different scope;
- productivity unsuitable for local conditions;
- duplication between a composition and a separate item.
Control needs to verify applicability, not merely the existence of a code.
The TCU requires an estimate compatible with the design and market, not a worksheet made up of official codes without engineering reasoning.
How to distinguish a correctable failure, a material failure, and possible gross error
A screening matrix helps avoid extremes.
| Criterion | Correctable failure | Material failure | Possible gross error |
| Materiality | Low | Medium or high | High or systemic |
| Technical evidence | Exists, but there is a formal error | Partial or inconsistent | Absent for a basic duty |
| Correction | Objective and without changing substance | Requires technical review | Would require reconstructing an essential decision |
| Available information | Was used, with a minor failure | Partially used | Clear evidence was ignored |
| Complexity | Low, isolated error | Medium | Inexcusable conduct even considering complexity |
| Effect | No material impact | May affect price or competition | Overpricing, improper procurement, or significant risk |
| Conduct | Diligent with a lapse | Insufficient control | High degree of negligence, recklessness, or lack of technical skill |
The last column is not an automatic finding of liability. It signals that the case requires individualized responsibility analysis.
A decision flow for reviewing estimate findings
This flow keeps correction of the estimate separate from personal liability.
Correcting the estimate comes before discussing fault
If an audit identifies potential overpricing before award, the administrative priority should be to eliminate the failure.
The process may require:
- review of quantities;
- update of the worksheet;
- new price research;
- design correction;
- republication of the tender;
- reopening of deadlines;
- due diligence on a proposal.
Liability assessment has its own procedure and purpose. Mixing the stages may generate defensive behavior and delay technical correction.
This separation helps address the decision paralysis in public works: strong control does not require managers to work under a presumption of fault.
A technical defense opinion must reconstruct facts, not create retrospective justification
When a control body raises a question, a useful technical opinion should explain the decision-making process using existing evidence.
The Engineering Technical Opinions service can structure an analysis based on:
- chronology of documents;
- authority of each official;
- design available on the relevant date;
- estimating methodology;
- price sources;
- quantity memorandum;
- warnings and reviews performed;
- materiality of the failure;
- actual or potential economic effect;
- possibility of correction;
- corrective measures adopted.
The objective is not to invent a later reason for an undocumented decision. It is to demonstrate, when it existed, the technical reasoning that supported the choice.
What characterizes a weak defense
Some justifications have little evidentiary force:
- “it has always been done this way”;
- “the system accepted it”;
- “the supplier provided the information”;
- “there was no intent to cause harm”;
- “the final price was below the estimate”;
- “no one noticed”;
- “it was urgent” without demonstrating the urgency;
- “the amount is small” without relative materiality analysis.
Absence of intent does not, by itself, resolve a discussion about gross negligence. The focus should be technical diligence.
A total price below the estimate does not cure every distortion
A procurement may have a total price below the estimate and still contain relevant internal problems.
Bid-sheet manipulation, excessive critical unit prices, or manipulated quantities may create risk of amendments and future payments.
For this reason, analysis needs to consider the price structure, not merely the overall discount.
At the same time, an isolated inconsistency in a low-materiality item should not be artificially magnified if it does not alter value for money or execution.
Proportionality remains necessary in both directions.
Design error and estimating error need to be separated
An estimate may faithfully reproduce an incorrect design.
If the design shows 1,000 meters of piping when the correct quantity would be 700, the estimator who uses 1,000 may have correctly performed the assigned task, depending on the scope and available warnings.
On the other hand, if the inconsistency was obvious and the professional had a coordination duty, the analysis changes.
A responsibility matrix needs to define:
- who measures quantities;
- who validates the design;
- who selects the composition;
- who researches prices;
- who reviews BDI;
- who approves the estimate;
- who verifies final consistency.
Assigning liability without individualizing duties produces a weak conclusion.
Independent review reduces the risk of gross error
A second line of review finds problems the original author may not perceive because of familiarity with the worksheet.
The reviewer should have sufficient independence to challenge assumptions and access source documents.
A review may test:
- totals and formulas;
- material quantities;
- official codes;
- custom compositions;
- prices of critical inputs;
- social burdens;
- BDI;
- duplications;
- omissions;
- consistency between design and worksheet;
- versions and base date.
In highly material projects, this stage functions as preventive control and evidence of institutional diligence.
The manager does not need to master every composition to exercise control
Managerial responsibility does not mean recalculating thousands of coefficients.
The manager needs to require a reliable process:
- identified responsible parties;
- calculation memorandum;
- appropriate sources;
- independent review;
- treatment of discrepancies;
- formal technical approval;
- version control.
If the governance system works, the decision-maker may rely on technical opinions within the corresponding areas of competence without automatically becoming responsible for every specialized error.
Decree No. 9,830/2019 expressly rejects automatic extension of responsibility from a technical opinion to the decision-maker, except where there is sufficient evidence for the decision-maker to perceive intent or gross error, or where collusion exists.
Red flags before publishing a tender
Some signs justify stopping and reviewing before publication:
- Class A item without composition or justification;
- quantity without source;
- estimate without base date;
- design and worksheet at different revisions;
- BDI without a memorandum;
- research based only on an interested supplier without justification;
- critical price well above a reference without analysis;
- custom composition without productivity;
- burdens incompatible with the applicable regime;
- absence of a detailed estimate when required;
- worksheet with broken formulas;
- material difference between subtotal and consolidation;
- contingency applied as an arbitrary percentage without identified risks.
Correcting these points before publication is far less costly than explaining them afterward.
Preventive checklist against serious estimating failures
Before final approval, verify whether:
- the design has maturity compatible with the estimating method;
- all material quantities have a supporting memorandum;
- units have been checked;
- SINAPI/SICRO were used when applicable;
- exceptions are justified;
- quotations are technically normalized;
- critical prices were researched with depth proportional to materiality;
- ABC Curves for services and inputs were reviewed;
- custom compositions have method and productivity;
- social burdens correspond to the correct regime;
- BDI has an analytical memorandum;
- contingencies derive from risks when applicable;
- the base date is consistent;
- formulas were audited;
- design and worksheet versions match;
- independent review was performed;
- identified discrepancies were recorded and resolved;
- technical responsibility is identified.
How A3A Engenharia structures an analysis of a questioned estimate
An independent technical analysis does not begin by asking “who made the mistake?” It begins by asking “what happened to the estimate?”
The sequence is:
- reconstruct the original estimate;
- preserve the base date;
- recover available sources and documents;
- recalculate critical quantities;
- compare prices;
- measure materiality;
- separate design, estimating, proposal, and execution errors;
- assess the possibility of correction;
- identify responsibilities;
- only then discuss liability and recommendation.
This approach reduces hindsight-based conclusions and concentrates the opinion on evidence.
Final considerations
Gross error in construction estimates is a category of liability, not an adjective for every imperfect spreadsheet. LINDB and Decree No. 9,830/2019 require gross negligence, involving a manifest, evident, and inexcusable error. Complexity, available information, causation, and diligence are part of the analysis.
TCU case law shows situations in which a failure may exceed the acceptable margin: unjustified quantities, clearly deficient market research, an estimate producing substantial overpricing, approval of a process lacking essential elements, and manifestly uneconomic choices without basis.
Conversely, the Court also applies moderate formalism to correctable failures. Decision 2,009/2025 shows that a cost composition using an incorrect wage floor may be corrected without disqualification when the total price is not increased. This example reinforces that correcting the process and assigning personal liability are different issues.
The best protection for managers, designers, and estimators is not eliminating every possibility of error. It is building a process in which quantities, prices, compositions, versions, and assumptions can be reconstructed. Calculation memoranda, the ABC Curve, independent review, and recorded decisions turn diligence into evidence.
Responsible control does not demand retrospective perfection. It requires material decisions to have been made with method, available information, technical competence, and justification proportional to the project’s materiality.
Technical references
[1] BRASIL. Decreto-Lei nº 4.657, de 4 de setembro de 1942. Lei de Introdução às Normas do Direito Brasileiro, as amended by Law No. 13,655/2018, especially Article 28. Available at: [Planalto — LINDB](https://www.planalto.gov.br/ccivil_03/decreto-lei/del4657compilado.htm).
[2] BRASIL. Decreto nº 9.830, de 10 de junho de 2019. Regulates Articles 20 to 30 of LINDB, especially Article 12. Available at: [Planalto — Decreto nº 9.830/2019](https://www.planalto.gov.br/ccivil_03/_ato2019-2022/2019/decreto/d9830.htm).
[3] TRIBUNAL DE CONTAS DA UNIÃO. Acórdão nº 3.569/2023-TCU-Segunda Câmara. Estimated budget, quantities, market research, overpricing, and gross error. Available at: [TCU — Acórdão 3.569/2023](https://pesquisa.apps.tcu.gov.br/documento/publicacao/3569%252F2023/%2520/DTRELEVANCIA%2520desc/0).
[4] TRIBUNAL DE CONTAS DA UNIÃO. Acórdão nº 2.459/2021-TCU-Plenário. Absence of quantity justification and gross error. Available at: [TCU — Acórdão 2.459/2021](https://pesquisa.apps.tcu.gov.br/documento/jurisprudencia-selecionada/Decreto-lei%25204.657%252F1942%2520E%2520%2528art.%252028%2529/%2520/score%2520desc%252C%2520COLEGIADO%2520asc%252C%2520ANOACORDAO%2520desc%252C%2520NUMACORDAO%2520desc/5/sinonimos%253Dtrue).
[5] TRIBUNAL DE CONTAS DA UNIÃO. Acórdão nº 2.121/2024-TCU-Plenário. Approval of tender documents without detailed estimate and price justification; liability and gross error. Available at: [TCU — Acórdão 2.121/2024](https://pesquisa.apps.tcu.gov.br/documento/publicacao/erro%2520grosseiro/%2520/DTRELEVANCIA%2520desc/16).
[6] TRIBUNAL DE CONTAS DA UNIÃO. Acórdão nº 2.009/2025-TCU-Plenário. Wage floor in cost composition, moderate formalism, and correction of the proposal. Available at: [TCU — Acórdão 2.009/2025](https://pesquisa.apps.tcu.gov.br/doc/acordao-completo/2009/2025/Plen%C3%A1rio).
[7] TRIBUNAL DE CONTAS DA UNIÃO. Engenharia de Custos em Obras Públicas: um guia de perguntas e respostas. Item 5.1.40. Brasília: TCU, 2026. Available at: [TCU — Infrastructure and publications](https://portal.tcu.gov.br/infraestrutura).
Frequently asked questions
It is a manifest, evident, and inexcusable error committed with gross negligence, characterized by a high degree of negligence, recklessness, or lack of technical skill, under Decree 9,830/2019. Personal liability requires intent or gross error.
No. Fault, materiality, available information, complexity, functional duty, causation, and diligence need to be analyzed. A bad outcome or the existence of damage does not automatically characterize gross error.
Yes, depending on the circumstances. The TCU has recognized that preparing procurement documents without justifying quantities may characterize gross error for sanctioning purposes.
Not necessarily. Robustness depends on relevance and the sources available. The TCU has considered serious an estimate based exclusively on potential suppliers, without adequate sizing and without considering similar procurements, when this produced substantial overpricing.
Not automatically. In Decision 2,009/2025, the TCU held that the composition may be corrected with a new worksheet, provided the total price is not increased and the proposal conditions are preserved.
No. Decree 9,830/2019 expressly states that the amount of damage, even if significant, cannot be used in isolation to characterize gross error or intent.
Maintain quantity and cost memoranda, use appropriate sources, review ABC Curves, justify exceptions, control versions, review BDI and burdens, perform independent review, and record relevant technical decisions.
Yes, provided it reconstructs facts, documents, assumptions, responsibilities, and materiality based on evidence. The opinion should not create retrospective justifications for decisions that were never supported.
Complementary technical materials
Related solutions
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- Cost Engineering for Construction and Engineering Services: quantities, compositions, BDI, and reference basis
- Engineering Technical Opinions: analysis, substantiation, and recommendation
Main content on the topic
- Public Works Estimating: how to structure quantities, costs, BDI, and risks
- Decision paralysis in public works: reducing fear of deciding without weakening control
