Based upon the practice at my agency, modifications to extend POPs for IDIQ contracts list the base contract number, and it's been understood that changes at the base contract level flow down to the task orders (deviating from FAR 17.204(e)). Recently, a senior contract specialist is questioning whether or not a deviation to extend the POP at the base level actually flows down to the task orders, which affects the date range of ordering periods (OP). The specialist's opinion is if a task order needs a longer OP, then it gets its own deviation. So, is it better to do a class deviation to apply across all the task orders under the IDIQ? The specialist's position stems from the definition of "contract action" and applying that a deviation is written for "a" contract action. Otherwise, multiple task orders under an IDIQ contract should require a class deviation if ordering periods need to be extended. Here are the FAR references used to generate the question: FAR 1.403, 1.404, 4.601, and 17.204(e).

Any insight is appreciated.

18 hours ago, 30-n-counting said:

[...] POPs for IDIQ contracts

[...] a task order needs a longer OP [ordering period]

[...] task orders under an IDIQ contract should require a class deviation if ordering periods need to be extended

I would look to FAR clauses 52.216-18 Ordering and 52.216-22 Indefinite Quantity (or whatever is in your contract) to clarify the difference between the period of performance (effective period) during which task order work can be performed (which is probably specified in both the IDIQ and the task order) and the ordering period during which orders can be placed against your IDIQ, which is only in the IDIQ (since you won't be placing orders against your task order). Clearly if you modify either the ordering period or the period of performance (effective period) of your IDIQ it will not change the duration of the work the contractor is required to perform under a task order, so no modification of dates in the IDIQ is "flowing down" to the task order.

But it sounds like maybe your question is if you intend to modify a task order to extend the period of performance beyond the five year limitation in FAR 17.204(e) do you need to get approval for all IDIQ task orders to potentially go beyond five years (although again, any actual modification to a task order period of performance would have to be made to that task order) or get approval for just the one task order to go beyond five years. I don't think that's a FAR question, it probably depends on both your agency procedures for approval and whether you have a need for longer periods of performance on all task orders or just one.

Or maybe I'm misreading the entire question, I'm confused by the implication that your task orders have ordering periods and that your agency practice has been to increase the duration of work to be performed under task orders via modifications to the IDIQ (what would the contractor even invoice against?)...

I don't understand the question. FAR 17.204(e) has to do with options. The OP didn't say the contract had options.

Why are you referencing FAR 17.204(e) when FAR 16.505 is the more appropriate reference for ordering periods for IIDIQ contracts? Also, you say, “The specialist's opinion is if a task order needs a longer OP, then it gets its own deviation." Task Orders don't have ordering periods, they have PoPs. Can you clarify what you are asking, as it's not apparent from your original post?