Can we use FY 12 O&M dollar to fund this as a project order?
The guidance that applies to your situation is found in the Federal Acquisition Regulation (FAR) at paragraph 32.703-3, Contracts crossing fiscal years. Further amendment of this policy can be found in the Defense Federal Acquisition Regulation Supplement (DFARS) at paragraph 232.703-3, Contracts crossing fiscal years. Since you are in the Army, I also checked for any additional supplementation in the Army FAR Supplement – there is none. As long as you comply with the FAR and DFARS limitations, the answer to your question is: yes. The key to this is to determine whether the effort involves severable or non-severable services since you are dealing with labor. If the labor is expended to produce an end product (e.g. reports), then that may be considered non-severable labor. It is best to seek the opinion of your legal counsel in making this determination.
Open full Question Details