Increase an existing J&A

[jason_a]

Hypothetical situation that I'd like to get a read from some other CO's out there. Let's say you have an existing class J&A (-6) for XX amount. You want to increase the ceiling for in-scope changes that does not exceed the original approval authority. Under the AAFARS Informational Guidance IG5306 it states:

Procedures for J&A changes

( b ) After approval.

(3) After contract award, if the dollar value of an in-scope change exceeds the original J&A approval authority or increases the approved J&A dollar value by 50 percent or more, the contracting officer shall submit an amended J&A to the appropriate approving official. Clearly identify changes from the approved J&A.

(4) A new or amended J&A is not required for:

(i) a decrease in the dollar value or scope of the effort;

(ii) an increase in the estimated dollar value of the in-scope effort except for an increase as described in (2) or (3) above.

So the question is can you increase a J&A under 50% without going to the original authority? Is it against CICA to do it? These are some of the questions that have come up. I've looked at the GAO, and COFC but couldn't find much on this. Thanks,

[Guest Vern Edwards]

If I read ((3) correctly, you must go to the approving official if (1) the in-scope change, by itself, exceeds the approval authority (FAR 6.304) for the original J&A or (2) if the in-scope change increases the approved dollar value of the J&A by 50 percent or more.

So, let's the say that the approval authority is $550,000 [FAR 6.304(a)(1)] and the approved dollar value of the J&A was $400,000. A $199,000 in-scope change (a) would not exceed the $550,000 approval authority and ( would not increase the dollar value of the J&A by 50 percent or more. Thus, it would not have to go to the approval authority. However, a $200,000 in-scope change would increase the dollar value of the J&A by 50 percent and thus would have to be sent to the approving official.

[Larry Edwards]

Jason, I agree with Vern Edwards here. The key term he used is ?in-scope.? The AFFARS Informational Guidance 5306 you cite has a page and a half immediately following your quoted section explaining scope and giving examples of when you would or would not do a revised J&A. Fairly small percentage increases that change what is being bought enough to be a change in scope will require a new D&F. The GAO has a fair amount of discussion on this point. Here is the link on WIFCON:

http://www.wifcon.com/pd6_001.htm

Because Vern did not have access to the page and a half following , I believe he may have gotten the first portion of his example wrong. $400,000 plus $199,000 would total $599,000 which would be over the original approval level of $550,000. I believe that would require a new D&F. If he had used $149,000 in his example, that would have totaled $549,000 which would not require a new D&F if it was in-scope.