Task order obligated on 9-7-21.  Two lines of accounting were used.  One line was 20/21 (2 year funds) and the other line was 21/22 (2 year funds).  So one line of funding expired last year on 9-30-21 and the other will expire on 9-30-22.  The requirement is severable services and the services are not separated between these two lines of accounting.

The agency wants to issue a no cost POP EXT to end on 1-6-24 due to "Government COVID delays..."  

From an appropriations law standpoint, how can we handle this request with part of the funds expiring on 9-30-21 and the other part will expire on 9-30-22?

Can we extend to 9-6-23 (two years from the original obligation) or is it 9-29-23 (two years from the expiration of the funds)?  How would we consider the part of the order that has already had it's funds expire? 

 

Is the contract funded annually?

Did the task order contain two line items, one for the services funded with what you call "20/21" funds and one for the services funded by "21/22" funds?

If not, why not?

The task order should only be funded once to accomplish the one consultation services task.  I say "should" because often then decide to add more money on these.

The task order did contain two line items.  

My assumption is that we can not extend the line item for the expired funds but we can extend the line item for the 21/22 funds as long as we do it by 9/30/22.  But do we extend to 9-6-23 (two years from the original obligation) or is it 9-29-23 (two years from the expiration of the funds)?

 

It appears that your question is about the availability of appropriations for obligation, but I'm not sure. Instead of asking you  a series of questions about the nature of the funding and the nature of the services, I'll refer you to the Government Accountability Office publication, Principles of Federal Appropriations Law, Volume 1, which you can find here:

https://www.gao.gov/assets/2019-11/202437.pdf

I think you may find your answer(s) in Chapter 5, Availability of Appropriations: Time.