There are several FAR clauses that apply only to contracts over a specific dollar amount, for instance, the simplified acquisiton threshold. Or, $650,000 is a frequently used amount. Is there anyone who has any guidance on these clauses if they are in a contract (or subcontract) which has a total dollar value below the threshold? Do the clauses become active if there is a modification or an option which later increases the amount over the threshold?
I would argue that they can't be applied to the aggregate amount, and thus, would never be applicable to the contract, unless a single option or modification added an amount over the threshold. For instance, if there is a contract in place for $75,000 and later a modification adds $30,000, this increase raises the total value over the simplified acquisition threshold. However, if you have already spent the first $75,000 with no regard for any clause that applies only to contract over $100,000, you obviously can't go back and spend the money in compliance with those clauses. So, does the clause apply to the additional $30,000, or not at all? On the other hand, if an option year added $150,000, I would think that the relevant clauses would apply to this amount. Is this an accurate interpretation?