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Since Other Transaction Authority does not require FAR and supplemental regulations, what is required when you are using subcontractors?    Is Sam.Gov registration required?   Is Commercial Determination Required?  Is cost and price analysis required?   Any help would be appreciated.   Want to get this right from the beginning.   We are the Prime in this.   Thanks! 

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Read your OTA agreement and find out what your responsibilities are.

OTAs should address the issues you're asking about, if they were contemplated during the negotiations.  If it isn't addressed in the OTA agreement, does your company have procedures in place for subcontracting?  

Above all, be smart and use good business judgment.  There are reasons for using OTAs and they frequently revolve around some of the issues you mention, so those issues are usually addressed in the agreement.

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