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gfsullivan

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About gfsullivan

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  1. If federal procurement regulations and laws do not apply to the Mint, what rules do? How can a contractor know what rights it has and what standards and rules the Mint must follow when deciding whether to respond to a solicitation from the US Mint? The same question applies regarding potential claims for contractors performing a contract with the US Mint. The US Mint has not made its acquisition rules and policies publicly available.
  2. Can anyone direct me to a link or file containing the US Mint procurement regulations? I know US Mint is exempt from having to use the FAR, but every time I search, I only get results pointing to the DTAR, which is not applicable to the Mint.
  3. It is not under SAT but used SAP procedures for acquisition as commercial and under $7M value (base + options).
  4. No, neither notice nor exercise dates have passed and neither will for a long time.
  5. Thanks for the feedback.
  6. @Vern Edwards The services are severable but it's no year funding. We would be buying more support in the base period but not able to buy the same level of support in the option. Do you still think we would have to compete or justify as some source the increase in the base PoP?
  7. Question presented: Are there any legal or regulatory (FAR, GAO opinions, case law etc.) impediments to reducing the level of effort (LoE) of an unexercised option year (subject to 52.217-9) and increasing the LoE by the same price in the base period of performance (PoP) of the contract via bilateral modification and not treating it as a sole source action subject to FAR 6? Factual background: In this instance, there will be no increase in overall contract price (including options). There will also be no increase in the overall LoE (including options). All PoPs (base and options) will remain unchanged. The contract is FFP for 6 FTEs of contractor support in the base and option periods.
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