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Portland1102

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  1. Good Morning! I typically use the DAU Clause Matrix to select clauses. A lot of my procurements are commercial items/services under Part 13 or 13.5. I realized when I select 'Commercial' (whether supply or service) in the matrix, it removes a lot of provisions/clauses as expected. However, I realized some of these removed provisions/clauses seem to plainly state that they apply to procurements over SAT. This causes me concern when dealing with a 13.5 SAP buy over SAT. Some of the removed clauses are 52.202-1, Definitions; 52.203-3, Gratuities, 52.203-17, Contractor Employee Whistleblower Rights and Requirement to Inform Employees of Whistleblower Rights; 52.204-4, Printed or Copied Double-Sided on Postconsumer Fiber Content Paper, & many others. The prescription for these is to include in everything over SAT; however, the DAU Clause Matrix infers to not use them in commercial procurements regardless of dollar value. I couldn't find any language in 52.212-1 thru -5 regarding gratuities or fiber content paper so it doesn't appear these are covered by the commercial provisions/clauses. I looked at the 2.101 definition for SAT but it appears to confirm that it does not increase along with the SAP threshold when utilizing 13.5. Could you point me to the regulation that permits the omission of 52.202-1, 52.203-3, 52.203-17, 52.204-4, 52.237-1, 52.237-2, 52.253-1, etc. when utilizing commercial procedures - or is there a big issue with the DAU Clause Matrix? My guess is that the folks at DAU are smarter than I, so please don't roast me if the answer is simple. I truly appreciate all of the guidance! If this belongs in the beginner section, please let me know and I will delete this and repost.
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