Consolidation approval.
Started by ArrieS · Mar 27, 2024 · 5 replies
- AOriginal post
ArrieS
Mar 27, 2024 · 2y ago
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.
- D
Don Mansfield
Mar 27, 2024 · 2y ago
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.
- A
ArrieS
Mar 28, 2024 · 2y 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.
- D
Don Mansfield
Mar 28, 2024 · 2y ago
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?
- A
ArrieS
Mar 28, 2024 · 2y 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).
- D
Don Mansfield
Mar 28, 2024 · 2y ago
No need for a written determination and I see no benefit in doing one.
Condition yourself to avoid red tape whenever possible.