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CAS applicability to delivery orders under IDIQ contracts

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I have an FFP IDIQ supply contract. The contract contains five option years; all with negotiated/priced CLINS established prior to the basic contract award.

Question: What portions of this contract are/ would be CAS covered? Would it be each delivery order, each option year (though exercise of an option year does not generate a delivery order), or the five year IDIQ contract in its entirety? I cant seem to find a clear answer anywhere and looking for some opinions. Thanks.

I think JMG's principal question is whether the CAS apply to each and every order under an IDIQ contract or on an order-by-order basis depending upon each order's attributes. JMG appears to assume that there is a statute, regulation, or policy that answers his/her question. If there is, I do not know about it. I believe that the long and the short of it is that whoever wrote JMG's contract should have thought of how the CAS would apply to orders -- whether across the board or case-by-case -- and provided an answer in the contract itself as one of its terms.

As to whether the CAS apply to each option year or the five year contract in its entirety, the answer seems obvious to me -- to the extent that they apply at all, they apply throughout the life of the contract unless the contract says otherwise.

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I think JMG's principal question is whether the CAS apply to each and every order under an IDIQ contract or on an order-by-order basis depending upon each order's attributes. JMG appears to assume that there is a statute, regulation, or policy that answers his/her question. If there is, I do not know about it. I believe that the long and the short of it is that whoever wrote JMG's contract should have thought of how the CAS would apply to orders -- whether across the board or case-by-case -- and provided an answer in the contract itself as one of its terms.

As to whether the CAS apply to each option year or the five year contract in its entirety, the answer seems obvious to me -- to the extent that they apply at all, they apply throughout the life of the contract unless the contract says otherwise.

Yes, you are correct in your assumptions, Vern. I was looking for a "smoking gun" of sorts. It is interesting that IDIQ CAS applicability may be dictated by the terms of the contract. One would think it would be engrained in statute or policy. It would be helpful if the FAR 30.202-6b phrase "CAS-covered contract" were defined in FAR 30.001, but it is not. I am inclined to abide by the definition of a contract in FAR 2.101 where I interpret each delivery order to be a contract, which is then applicable to the CAS. Just my thought process. Agree this could be clarified in the terms of the contract to alleviate debate. Thanks.

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