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  • Question

    Does CAS apply to all contracts of an IDIQ MATOC that has capability to award cost reimbursement task orders as well as fixed price task orders?


    Answer

    The definition of a contract when considering application to an ID/IQ is the entire contract as a whole, not a task or delivery order.  Note this differs from a Basic Agreement or Basic Ordering Agreement in that BAs and BOAs are not considered contracts.  (See FAR 16.5 - Indefinite Delivery Contracts, as compared to FAR 16.702(a)(2) and FAR 16.703(a)(3) - Agreements). The dollar amount used is the total maximum value that may be ordered under the contract.  See FAR 1.108 FAR Conventions which states, “(c) Dollar thresholds. Unless otherwise specified, a specific dollar threshold for the purpose of applicability is the final anticipated dollar value of the action, including the dollar value of all options. If the action establishes a maximum quantity of supplies or services to be acquired or establishes a ceiling price or establishes the final price to be based on future events, the final anticipated dollar value must be the highest final priced alternative to the Government, including the dollar value of all options.”  

    So, given the above facts, it appears your proposed action will be subject to CAS, unless your proposed action meets one of the specific exemptions for CAS exemption listed at
    9903.201-1 CAS applicability.



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