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  • Question

    Is filling out a DD2579 required to modifications to MILCON projects?


    Answer

    DFARS 219.201(d)(10) states:  "Contracting activity small business specialists perform this function by—(A) Reviewing and making recommendations for all acquisitions (including orders placed against Federal Supply Schedule contracts) over $10,000, except those under the simplified acquisition threshold that are totally set aside for small business concerns in accordance with FAR 19.502-2. Follow the procedures at PGI 219.201(d)(10) regarding such reviews.  (B) Making the review before issuance of the solicitation or contract modification and documenting it on DD Form 2579, Small Business Coordination Record; and"

    The
    PGI 219.201(d)(10)(A) (2) procedures state:  "Modifications that increase the scope of the contract, or the order under a Federal Supply Schedule contract, should be reviewed by the small business specialist. At a minimum, these actions might impact the small business subcontracting plan. However, funding modifications or modifications that do not increase the scope of the contract generally should not be reviewed, because the value that a small business specialist review would add in these instances would be minimal compared to the resources that would be expended."

    Based on this analysis, if your modification is within the scope of work of the contract you should not be required to complete a DD 2579 for it.  However, the PGI also says "generally should not be reviewed" so if your small business coordinator wants it reviewed and is following agency policy, then you should submit them a form.  You should have this discussion with your small business coordinator to see if should really be required for "all" MICON projects as you state.  Good luck.

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