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  • Question

    If the award exceeds the $50M CAS trigger threshold but part or most of the contract is for the procurement of commercial items, does this award trigger CAS coverage for the contractor?


    Answer

    You are referring to the $50 million threshold for whether modified CAS coverage or full CAS coverage applies. If the contract is awarded using FAR Part 12 procedures, then the contract (taken in its entirety) is considered a commercial contract. The FAR Appendix (AP1, 9903.201-1 CAS applicability, (b)(6)) states that "...contracts and subcontracts for the acquisition of commercial items" are exempt from all CAS requirements. This tells us that the exemption applies at the contract level, not the line item level. The Government contracting officer will make the necessary determination.

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