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  • Question

    Does DPAS apply to a commercial item? Can a Prime flow down DPAS requirements on "dual use" items?


    Answer

    DPAS can apply to commercial items. The DoD DPAS Manual (DoD 4400.1-M dated 21 Feb 2002) does not restrict commercial items from having a rating. In addition, the Code of Federal Regulations, Title 15 (Commerce and Trade) Part 700 (DPAS), subsection 700.17 (use of rated orders) has the following items under letters (e) and (f).
     
    "(e) a person may palce a rated order for the minimum commcercially procurable quantity even if the quantity needed to fill a rated order is less than the minimum. However, a person must combine rated orders as provided in paragraph (c) of this section, if possible, to obtain minimum-procurable quantities.

    (f) A person is not required to place a priority rating on an order for less than $50,000, or one half of the Federal Acquisition Regulation (FAR) Simplified Acquisition Threshold (see FAR 2.101), whichever amount is larger, provided that delivery can be obtained in a timely fashion without the use of the priority rating."

    Obviously Title 15 Part 700.17(f) states that a priority rating does not need to apply for amounts less than $50,000, or one-half of the SAT threshold. This does tie in DPAS to commcerial items.

    Thye prime contractor should specify which parts needs the DX or DO rating. 


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