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good afternoon,

i have been researching CSOs as The How with 10 USC 4022 as the What. I read DFARS 212.70 that CSOs are limited to fixed-price, including fixed-price incentive contracts. Since an OT is not FAR based are we still beholden to the fixed-price obstacle? I would assume no, but wanted some insight from the masses. much appreciated.

The restriction on contract type comes from 10 USC 3458(c)(2):

"Contracts or agreements entered into using the authority under subsection (a) shall be fixed-price, including fixed-price incentive contracts."

If you set your CSO up like DIUx or MDA then no. You can solicit using a CSO and award an other transaction using a non-procurement authority that isn’t fixed price. You just wouldn’t use the procedures in the DFARS. It’s a solicitation IAW the rules in the statute of the non-FAR based authority you are trying to use.

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@uva383 good morning. that is the route i aim to pitch to the customer. i appreciate the reply and ensuring i was on the right track.

On 10/29/2025 at 3:42 PM, uva383 said:

If you set your CSO up like DIUx or MDA then no. You can solicit using a CSO and award an other transaction using a non-procurement authority that isn’t fixed price. You just wouldn’t use the procedures in the DFARS. It’s a solicitation IAW the rules in the statute of the non-FAR based authority you are trying to use.

So just ignore 10 USC 3458(c)(2)?

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