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D&F for Consolidation of Contract Requirements


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Having a major debate between Legal and Policy regarding the requirement for a consolidation D&F. NDAA 2013 repealed 10 USC 2382 which required D&F for DoD over $6M, on Jan 2nd. On Jan 3rd, Small Business Act in Section 44 requires a D&F at $2M for all Federal agencies.

DFARS still requires the D&F, I haven't seen anything in SBA regulations or the FAR or from DPAP on this matter. Maybe we all are missing something. Any thoughts would be appreciated.

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