Regarding the relationship between CLINs and ACRNs:
(1) May contracts governed by the DFARS be written at the ACRN level (i.e. without CLINs)?
(2) May contract payments governed by the DFARS be entitled/paid at the ACRN-level (i.e. without a CLIN)?
Thank you for your assistance.
Let’s start at the FAR, FAR 4.1001 states: “Contracts may identify the items or services to be acquired as separately identified line items. Contract line items should provide unit prices or lump sum prices for separately identifiable contract deliverables, and associated delivery schedules or performance periods. Line items may be further subdivided or stratified for administrative purposes (e.g., to provide for traceable accounting classification citations).
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So the FAR says “may” on CLINS, certainly not mandated at this point. The questioner is from DFAS, therefore we can assume that the issue is with DOD. So let’s see what the DFARS says.
DFARS 204.7103-1 Criteria for establishing (referring to Line Items). “Contracts shall identify the items or services to be acquired as separate contract line items unless it is not feasible to do so.”
So this is kind of a mixed message, at first it says you shall, then lets you off the hook by allowing you not to if “not feasible to do so.” Therefore the answer to the questions is you shall, unless not feasible.
To answer your second question, if a contract doesn't have CLINS it would still require an ACRN to pay for the contracted work. So CLINS or no CLINS you still need money (ACRNs).