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CSimcox

Clarification of the IMM Program in DFARS PGI 208

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We currently have a BOA to procure metals as DLA Aviation is unable to procure them for us. DLA sends the request to the AF and we order then have them delivered to DLA then DLA will issue back to the AF the metals as they are needed. DLA Troup Support is the IMM Manager according to the DFARS PGI 208-7004 and they have an active Prime Vendor Contract but DLA Aviation says that they cannot use the Prime Vendor program so the AF will still have to support them in purchasing the metals. 

Question: According to the IMM Program DFARS PGI 208.7003-1(b)(ii) states that anything over the simplified acquisition threshold has to have a waiver, but DFARS PGI 208.7003-1(b)(i) states that anything under the SAT and above the micro-purchase threshold is at the discretion of the Contracting Officers to justify a local purchase. Would my 5 year BOA's need a waiver for the Basic or would the Contracting Officer be able to do independent justifications for each order as they are all under the SAT? Is there more instruction to clarify this as the DFARS is not clear if repeating orders are still considered single orders.

What is the intent of the IMM Program if we have 5 year work arounds?

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