Use of Options

17.205 is preaward.

“Determination and Findings means a special form of written approval by an authorized official that is required by statute or regulation as a prerequisite to taking certain contract actions.” FAR 1.701.

Neither FAR reference you cited call for a D&F.

FAR 17.205(a) is justifying the inclusion of options (pre-award). DAU says this:

”The contracting officer shall include a written justification for the quantities or the term under option, the notification period for exercising the option, and any limitation on option price under FAR 17.203(g) in the contract file (FAR 17.205).”

My thoughts in support of those already provided - 

ContractingGuy said:

Is there a requirement to execute a pre-award D&F or Justification for using options in a non-Part 14 award?

Yes a justification (I have used lower case on purpose)  in as much as you need to "justify" certain  elements of the option being solicited per the reference you have already cited - FAR 17.205 - but not a D&F. 

I have always remembered this quote by Vern Edwards -  "All determinations and findings include determinations, but not all determinations are determinations and findings."

Maybe this is a twist on the quote - All justifications and approvals include approvals but not all justifcations include approvals.

I like it, Carl.

All determinations require findings, but not all determinations require D&Fs under FAR subpart 1.7. Similarly, not all justifications require justification and approval under FAR part 6.

These eight are the only imperative "D&F" statements this community located a decade ago, in FAR:

1. 6.202(b)(1) - establishing and maintaining alternative sources;

2. 8.404(h)(3)(ii)(A) - use of T&M;

3. 12.207(b)(1)(ii)(A) - use of T&M;

4. FAR 16.401(d) - use of incentive- and award-fee contacts;

5. 16.601(d)(1) - use of T&M;

6. 17.502-2(c) - Economy Act;

7. 25.202 - Buy American, construction materials; and

8. 25.1001 - waiver of right to examination of records.

Any FAC since then could have added one, so keep a look out in FAR.  Also, your Agency FAR Supplement may add to this list.

From a very good read: