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jb208

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  1. It was getting pretty late at night here, but I would just like to clarify and provide a context to what I meant by: We issue a synopsis to advertise proposed contract actions to the public and various stakeholders. The reason we advertise is because it's reasonable to believe that there are stakeholders who may have an interest in what the government is doing. In the case of government contracting, the interest we are serving is providing opportunities for contractors to earn the government's business (aka competition). What I should have said to have been more clear is that t
  2. Thanks again for your response. My thoughts on the synopsis requirements were leading me to the same conclusion. The FAR is a continual work in progress, and I catch changes here and there that don't always make sense, only to research and find that the discrepancy has been corrected. Gong back to Mr. Mansfield's question, my view of the synopsis is that it's intent is to advertise or provide notice of a contract action where competition is normally required. It tells interested parties what our intentions are in those instances where the public benefit of the notice outweighs the admini
  3. ji, To shine some light on our micro-purchase issue, FAR 13.201( g )( 1 ) provides two thresholds for declared contingencies: (i) $20,000 in the case of any contract to be awarded and performed, or purchase to be made, inside the United States; and (ii) $30,000 in the case of any contract to be awarded and performed, or purchase to be made, outside the United States. So with our office being outside the U.S., where is the purchase actually being made when we buy from a U.S. based company? Is it being made overseas, or where the company is located? I've tried to look at th
  4. ji20874, Thanks for your response. You are right that the exception is FAR 5.202( a )( 12 ) and not FAR 5.202( a )( f ). I didn't double check my reference before I typed it in. The main issue with the exception at FAR 5.202( a )( 2 ) is that we're in the sustainment phase of the contingency, and most of the items we're purchasing can't reasonably be justified as being required under unusual and compelling urgency. Mr. Edwards, I always appreciate your direct responses. Regarding the $25k requirement to synopsize, wouldn't FAR 13.203( a )( 2 ) take precedence if the applicab
  5. I'm a contracting officer currently working overseas in support of a declared contingency for the Department of Defense. We're having a spirited discussion in our office on synopsizing requirements. The most hotly debated topic is the requirement to synopsize through the GPE for requirements >$30k (micro-purchase threshold) when soliciting competition in the United States. FAR 13.106-1( c ) states that oral solicitations can be used when notice is not required under FAR 5.101 and the acquisition does not exceed the SAT ($1M for overseas declared contingency). But FAR 13.106-1( c ) a
  6. None of the exceptions at FAR 25.401 apply to this acquisition, except the possibility of using a set-aside. Regarding the use of a set-aside, I was anticipating using full and open competition to waive the BAA on the basis of non-availability IAW FAR 25.103( b ). However, I think this is where I started leading myself astray. I was reading FAR 25.103( b )(3) and saw that a written determination of non-availability is not reqired when using FAOC and no offers for domestic end products are received. Even though my market research is very comprehensive, I question whether my agency would agre
  7. In any given year, the aggregate value of calls against a single BPA would likely be anywhere from $150k to $1M, with most exceeding $204k. FAR 25.403( b )(3) certainly helps to substantiate the applicability of the TAA. If I follow where you're going with this, I'm anticipating your thoughts are that FAR 13 BPAs should be treated analagous to contracts under the BAA and TAA, and that the acts not only apply to the BPAs themselves, but also to each individual call against the BPA, regardless of individual call dollar value?
  8. Here's the situation: I'm looking at awarding multiple FAR 13 Blanket Purchase Agreements for the repetitive purchases of commodities well below the micro-purchase threshold. The commodities being purchased all perform the same general function, but they come in different shapes, sizes, colors, and materials. We don't know what exact item we need until the actual need arises, preventing the consolidation of orders. No single purchase will exceed the micro-purchase threshold, and the total value of all purchases made under each BPA is reasonably expected to exceed $500,000. How does the Buy
  9. I'm in VA. I've checked our agency supplement, but haven't found anything that forces us to use options.
  10. Thank you, Vern. Your reputation precedes you. We all generally agreed that this is not multiyear, and I do appreciate your insight as well. The inclusion of options is what was preventing us from reaching a unanimous desicion. I can't find anything, anywhere that states options are required for an IDIQ contract to establish the ordering periods. But, this pushes some people out of their comfort zones when it deviates from how they were taught. I volunteered to undertake the impossible and demonstrate that beyond the absence of regulation mandating the use of options, options are not req
  11. This is excellent information. but it still leaves the question of whether or not options are "required". To add to the debate, another person asked if we had reviewed the definition of a multiyear contract at FAR 17.103 and applied it to our scenario. We have. FAR 17.103 states that a multi-year contract is for the purchase of supplies or services for more than 1, but not more than 5, program years. A multiyear contract amy provide that performance under the contract during the second and subsequent years of the contract is contingent upon the appropriation of funds, and (if it does so pro
  12. I'm working on preparing a multiple-award IDIQ for FFP commercial supplies, and there has been some discussion in my office about multi-year vs. multiple year and the inclusion of options for ordering periods. Each multiple-award IDIQ is intended to have a single five-year ordering period without options. Each delivery order would be funded using single-year appropriations. Each IDIQ would also have a minimum obligation that we reasonably expect will be fulfilled almost immediately after award. However, these IDIQ's raise two very important questions: 1. Would the IDIQ's be considered multi
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