Posted September 17, 20204 yr comment_54840 c) If the Contractor does not have an approved purchasing system, consent to subcontract is required for any subcontract that - [...] (2) Is fixed-price and exceeds - [...] (ii) For a contract awarded by a civilian agency other than the Coast Guard and the National Aeronautics and Space Administration, either the simplified acquisition threshold, as defined in FAR 2.101 on the date of subcontract award, or 5 percent of the total estimated cost of the contract. Which one applies? The SAT or 5% of the total contract cost? I always thought that consent is required for Fixed Price Subontracts which exceed SAT. What if the total contract is at $70 MIL of estimated cost. Would consent be required at $250,000 or at $3.5MIL? It does not say "greater of" or "lesser of" It is the same issue with Alternate I for notifications for fixed price subcontracts. Thanks as always.
September 17, 20204 yr comment_54843 If it exceeds either one. Or, in other words, whichever is lower.
September 17, 20204 yr Author comment_54845 8 hours ago, Don Mansfield said: If it exceeds either one. Or, in other words, whichever is lower. Many thanks, Don.
September 17, 20204 yr comment_54846 14 hours ago, Tzarina of Compliance said: Which one applies? The SAT or 5% of the total contract cost? Both. Read it as either or. In other words, it’s required if either condition or both conditions are met.
