Good Morning - 

I have a scenario in which we received a mod for option year 1 after completion of the base year, but after asking the CO why CLIN numbers weren't updated, he states that the CLIN numbers will remain the same for option year 1 like the base year, and unused funding will roll forward if it's listed on the auth. hours sheets. Any funds that need to come off would be reflected in a de-obligation and modification to the authorized hours sheet. 

I've never seen the CLIN numbers not be updated for the next option year. Is there an issue with this procedure or has anyone seen this before?

Thank you

 

It’s not uncommon.  All the CO is doing is using existing obligated funding.   Agencies financial practices, accounting, and types of funding vary.  As long as the CO tells you it’s okay, you’re fine.

Each option year should have been assigned its own CLIN at the time of solicitation.  You shouldn't have to update them. Using the same CLIN for the base year and an option year is inconsistent with FAR 4.1003.

1 hour ago, Vern Edwards said:

Each option year should have been assigned its own CLIN at the time of solicitation.  You shouldn't have to update them. Using the same CLIN for the base year and an option year is inconsistent with FAR 4.1003.

True.  But it’s sometimes done this way to use existing money.  With many automated contract/finance systems, new funding is required for a new CLIN.  It’s difficult to transfer unused funding from an old CLIN to a new option period.  I’m not saying it’s proper from a contract standpoint, but it happens.  

Thank you Vern and Formerfed! I really appreciate your feedback!

A lot of it has to do with the work, severable vs. non-severable, in addition to the type of funding that is used (annual appropriations vs no year / multiple year funding).

It would be nice to be able to use up all the funding as obligated before digging into the next pot, however, appropriation law seems to get in the way.