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Rule of Two when placing a MATOC


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I am currently getting push back from the Small Business Advocate that I have to meet the "Rule of Two" on a Multiple Award IDIQ I am working on posting to industry (a master IDIQ not a TO against an existing IDIQ). There are only 2 small  business contractors identified as "maybe" viable. I know about the GAO and COFC conflicting positions on the Rule of Two but, as I understand it, that pertains to EXISTING MAIDIQ. I can't find anything that speaks to trying to place the base MAIDIQ. I need a pool of at least 5-6 responsible contractors to bid and supply the Task Orders that I need. I will need 6 Task Orders immediately upon award of the IDIQ at 6 locations around the US all far above the SAT. Small Biz is claiming I need to set it aside for small business since I identified 2 small businesses available to bid. This assumes both contractors would be found technically acceptable and each be awarded a contract under the IDIQ. Then they would both need to compete for the 6 Task Orders and be able to supply them all. This seems unreasonable. Two contractors is not enough.

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