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Zag2009

NAICS Codes Requirements

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My company issued a BOA to a subcontractor under NAICS 236210, Industrial Building Construction.  Since then, several releases have been issued under the BOA under the same NAICS code.  One of the releases, however, involves no physical construction work and is only for training.  FAR 19.303 provides guidance and selecting the appropriate NAICS code, stating the NAICS code should be selected that describes the principal purpose of the product or service being acquired.  My question is do we select the NAICS code based on the principal purpose of the BOA itself or each individual release?     

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The BOA is not a contract. Your "individual releases" are the contracts.

Does that help?

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5 minutes ago, here_2_help said:

The BOA is not a contract. Your "individual releases" are the contracts.

Does that help?

Good point.  That is helpful.  Thanks.

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I presume you have a prime contract with the government that relates to the BOA.  If that is the case, are the training services being acquired as a result of a government requirement?  If so, is the training within the scope of the prime contract?

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2 minutes ago, Retreadfed said:

I presume you have a prime contract with the government that relates to the BOA.  If that is the case, are the training services being acquired as a result of a government requirement?  If so, is the training within the scope of the prime contract?

The scenario is we are the prime contractor awarding a BOA to a subcontractor for construction work.  Site training is required for the subcontractor to perform the work under the BOA.  Typically, training is a minor part of the scope of each release.  However, in one case, they issued a separate release for training, not tied to a specific release.  The question is can that training release fall under the same NAICs code of the overall BOA even though there is not physical construction work.  The BOA has zero funding and just a generic scope definition, with each release having individual funding and scope.  If you consider from that perspective, I would think each release would have a separate NAICS code.  Hopefully this explanation is clear.   

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3 hours ago, Zag2009 said:

FAR 19.303 provides guidance and selecting the appropriate NAICS code, stating the NAICS code should be selected that describes the principal purpose of the product or service being acquired.  My question is do we select the NAICS code based on the principal purpose of the BOA itself or each individual release? 

Are you asking this in regard to developing or complying with a small business subcontracting plan or for some other purpose?  If it is the latter, what clause in your contract requires you to assign a NAICS code to subcontracts?  If it is the former, because each "release" under a  BOA is treated as a separate contract, you would assign a unique NAICS code to each "release" using the guidance in 19.303.

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14 minutes ago, Retreadfed said:

Are you asking this in regard to developing or complying with a small business subcontracting plan or for some other purpose?  If it is the latter, what clause in your contract requires you to assign a NAICS code to subcontracts?  If it is the former, because each "release" under a  BOA is treated as a separate contract, you would assign a unique NAICS code to each "release" using the guidance in 19.303. 

Compliance with small business plan.  Your response supports my interpretation, that each release would be assigned a unique NAICS.  Thank you.

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