Great. Thank you.
So, just so I am clear, there is nothing wrong with negotiating reductions in quantities or unit price to stay under $150,000, particularly if the initial expectation was that the contract would fall under the $150,000 SAP. This is true even if the contract is awarded through a manual evaluation instead of an automated evaluation?
But there is a distinction/there is something wrong going on when the contracting officer breaks up a contract into 2 separate contracts to keep each contract under the $150,000 SAP threshold?
(c)(1) The contracting officer shall not use simplified acquisition procedures to acquire supplies and services if the anticipated award will exceed—
(i) The simplified acquisition threshold; or
(ii) $7 million ($13 million for acquisitions as described in 13.500(c)), including options, for acquisitions of commercial items using subpart 13.5.
(2) Do not break down requirements aggregating more than the simplified acquisition threshold (or for commercial items, the threshold in subpart 13.5) or the micro-purchase threshold into several purchases that are less than the applicable threshold merely to—
(i) Permit use of simplified acquisition procedures; or
(ii) Avoid any requirement that applies to purchases exceeding the micro-purchase threshold.