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    Who is the signature authority for this CPFF Contract Type D&F?


    A Determination and Findings  or “D&F” is 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.  “When a D&F is required it shall be signed by the appropriate official in accordance with agency regulations.  Authority to sign or delegate signature authority for the various D&F’s is a shown in the applicable FAR part.”  FAR 1.107.

    FAR Part 16 specifies that a D&F is required for all incentive- and award-fee contracts (FAR16.401(d) and for time and materials contracts (FAR 16.601(d)(1)).  Neither the FAR nor the DFARS specifically requires a D&F for Cost Plus Fixed Fee (CPFF) contracts, however, the FAR does require a written acquisition plan for CPFF,  approved and signed at least one level above the contracting officer, and that plan must include the rationale for using that contract type.  See FAR 16.306, 16.301-3(a)(2) and 16.301-2(b).

    You should also investigate whether you have a local policy for use of the D&F format in this case.  If so, it is logical to expect that signature authority would be at least as high as that required for the written acquisition plan (i.e., one level above the contracting officer). 

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