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I'm working on a large dollar Advisory and Assistance Contract that is about to be transferred from DHS to USDA. Congressional approval was granted for DHS to transfer funds to USDA, These funds are FY18 two year funds which we anticipate receiving around August/September. I know we have until end of FY19 to get these funds obligated before they expire but what I'm trying to figure out is how long the funds remain useable. When using annual appropriations, bonafide need allows one year from date of obligation to use the funds (crossing fiscal years) unless we are purchasing a non-severable service. We believe the services would be severable so would we still be limited to one year from obligation to use the funds. Really wish I still hand my CON090 Time, purpose, color of money slides. I've been looking through the redbook but coming up short. In my career I've only ever used annual appropriations and no-year funds.

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The more I think about it, I believe it's really just a bonafide need issue. If it's severable, we only have the year since we're crossing fiscal years.

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Does FAR 32.703-3(b) and/or 37.106(b) give you any flexibility?

Note that for both of these, I am pointing to para. (b), not para. (a).  Para. (a) deals with annual appropriations, so is not applicable to our discussion.

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Ask the budget official certifying the funds as available for use.  Part of that person's burden when certifying funds is to make sure the time/purpose/amount tests are satisfied.

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