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Congressional Notification for Termination

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Hello. I have a Single Award IDIQ with 3 open Task Orders. We are in the process of Terminating for Convenience. DFARS 249.7001 states, "Congressional notification is required for any termination involving a reduction in employment of 100 or more contractor employees." There is confusion on whether this requirement is at the IDIQ level or Task Order level.  There are some within the PM that think that if each Task Order has less than 100 employees affected, then we do not need to notify Congress, but if its at the IDIQ level and the total amount over all three Task Orders is 100+ then Congressional Notification is needed. I have not seen any regulation that specifies this requirement. Any guidance is appreciated. 

The regulation says "any termination."

Are you terminating each order separately, so that there are three distinct terminations, or are you terminating the contract and all on-going orders in a single action?

Don't answer. Just think about it.

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