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cdhames

Awkward publishing threshold - $10K - $15K for 2579's

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I may be missing something; maybe a memo published in an earlier year -it's been awhile since I worked small services; but the DoD (and AFFARS) regs still seem to require a 2579 filed for any requirement over $10K.

The publishing threshold under FAR 5.101(a)(2) changed awhile ago, from $10k to $15K (to display in a public place for 10 days; or in lieu of a public notice board, any electronic means, i.e., the GPE FBO -i hear some agencies allow $15 - $25k to be posted on Facebook but that's a different discussion).

On the DD Form 2579 there's a little box (Block 13 - Synopsis Required) where we're supposed to check whether or not a synopsize a requirement: Yes or No. If No, we're supposed to cite the exception to publicizing (it even has a note that reads, "if 'No', cite FAR 5.202 exception").

I have a project that falls within this awkward range of $10K to $15K.

Accordingly, DFARS 219.201(c )(10) requires review for all projects over $10K, and that review must use the DD Form 2579. AFFARS 5319.201(d)(10)( B ) reiterates this requirement for a $10K review on the 2579.

So, to summarize, there's no publishing requirement for contracts valued at, or under $15K. Yet we're required to file a DD Form 2579 for projects above $10K and cite a reference for an exception to synopsize.

I spoke with my Small Business specialist and that person could not provide specific guidance, however; that person does expect me to use a FAR 5.202 exception, or to synopsize the requirement. I don't blame them because the regs seem contradictory but clarification would be nice.

Has anyone experienced this, and what are your solutions?

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There is a synopsis requirement for actions over $25,000 -- see FAR 5.101( a )( 1 ) and 5.201( b )( 1 )( i ).

There is a display requirement for actions between $15,000 and $25,000 -- see FAR 5.101( a )( 2 ).

There is a small business review requirement for actions over $10,000 -- see the DFARS and AFFARS citatations in the original posting.

If your action is $8,000, none of the above applies.

If your action is $12,000, only the small business review requirement applies.

If your action is $18,000, both the small business review and the display requirement apply. There is no FAR 5.202 exception to synopsis for you to cite because there is no 5.201 requirement for synopsis. For the DD 2579, you might check NO and insert "N/A" or "See FAR 2.101( b )( 1 )( i )" or "Under $25K" in the text field in block 13.

This is not the first time that a form or an automated system fails to comply with the FAR.

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and the display requirement apply. There is no FAR 5.202 exception to synopsis for you to cite because there is no 5.201 requirement for synopsis. For the DD 2579, you might check NO and insert "N/A" or "See FAR 2.101( b )( 1 )( i )"

Did you mean "See FAR 5.201( b )( 1 )( i )"?

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