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I have a substantial CPFF Contract awarded to my company at one location. We have a location in a different state (different cage code etc.) that will work on the contract as well via an IOT. The out of state location has an approved purchasing system whereas my location does not.

The out of state location is planning to issue a subcontract. Keeping in mind, the contract was issued to my location without the approved purchasing system which ACO gets the notification/consent request? Mine or the one at the other company location. Also, is consent required or advanced notification? (if issued from my purchasing department at my location definitely requires consent.) There's NRE in the subcontract, otherwise its FFP and its in access of 5% contract value.

Edited by siwilliams

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FAR 52.244-2 is the key clause. You need to look at FAR 52.244-2(d) to see if the CO made any special provisions. Provided there are no special provisions, your sister company should not have to obtain consent or advance notification based on FAR 52.244-2( c ). One way to think about it is like you have two purchasing departments at your single company. The government has approved one purchasing department to place subcontracts. But the government wants to review the work of the other purchasing department before placing subcontracts.

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What do you mean by "location"? Do you mean a separate organization within a corporation? Do you mean a separate office or plant of your part of a corporation? An affiliate? Please be precise. And by "IOT" do you mean interorganizational transfer? Are you making up an acronym, or what? i could find no reference to "IOT" in any part of the FAR System.

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The nuances of IOTs vs subcontracts is a frequently asked WIFCON question. It belongs in the FAQ Vern is working on.

Generally, IOTs are make and not buy but sometimes they are buy and not make. This is all covered at FAR 15.4. A quick Google search using the term "interorganizational transfer accounting" would have turned up some good info.

Finally, to Vern's point, IOT used to be a commonly used acronym for "inter-organizational transfers" but now most people use it to refer to the "internet of things" and so we are better off using a non-ambiguous term.

Hope this helps.

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SI, to understand your problem, can you tell us why there is an issue as to whether your other division would need to get consent to issue the subcontract? Isn't your division the contractor? If you are not awarding the subcontract, why would you need to obtain consent? These are not rhetorical questions as I'm interested in your thought process and reasoning on this.

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