ArrieS Posted March 27, 2024 Report Share Posted March 27, 2024 Hello, I am having trouble determining who would sign my J&A for Consolidation. I work for a Navy laboratory and I have a consolidation that is estimated to be $20 million. I am confused by the language in Annex 4 which says "Approval granted to increase current consolidation of contract approval thresholds from $2 Million to no more than $50 Million for STRL and less than $100 Million for Head of Contracting Activity (HCA)." Is it saying that the threshold established in FAR 7.107-2(a) is raised from $2 million to $50 million and is approved by the HCA if between $50 and $100 million? If so, who is the approving authority for below $50 million, the KO? If the threshold is raised to $50 million, does that mean the stricter requirements of FAR 7.107-2(a) are not required and there is a lower threshold for justification required implied by the increase in the threshold? Or, am I mistaken, who is the approval authority for less than $2 million and the justification requirements? I am on a small procurement team and no one has done this before so I'm in the dark and curious. Quote Link to comment Share on other sites More sharing options...
Don Mansfield Posted March 27, 2024 Report Share Posted March 27, 2024 I'm confused, too. It doesn't make sense. Having said that, I think the deviation relieves STRL from having to comply with FAR 7.107-2 for contracts < $50 million. Quote Link to comment Share on other sites More sharing options...
ArrieS Posted March 28, 2024 Author Report Share Posted March 28, 2024 16 hours ago, Don Mansfield said: I'm confused, too. It doesn't make sense. Having said that, I think the deviation relieves STRL from having to comply with FAR 7.107-2 for contracts < $50 million. So no need for a determination in writing? Having said that, would it be best to still make a determination? Or, if factoring in the possibility of this being protested it would be best not to document that. Quote Link to comment Share on other sites More sharing options...
Don Mansfield Posted March 28, 2024 Report Share Posted March 28, 2024 Well, ASN(RDA) relieved STRL from the burden of the making the determination. How do you think they would react if you did it anyway? Quote Link to comment Share on other sites More sharing options...
ArrieS Posted March 28, 2024 Author Report Share Posted March 28, 2024 46 minutes ago, Don Mansfield said: Well, ASN(RDA) relieved STRL from the burden of the making the determination. How do you think they would react if you did it anyway? I don't know... I've never had any interaction with ASN(RDA). Quote Link to comment Share on other sites More sharing options...
Don Mansfield Posted March 28, 2024 Report Share Posted March 28, 2024 No need for a written determination and I see no benefit in doing one. Condition yourself to avoid red tape whenever possible. Quote Link to comment Share on other sites More sharing options...
.gif)
Recommended Posts
Join the conversation
You can post now and register later. If you have an account, sign in now to post with your account.