Why are the approval threshholds at FAR 13.501 greater than the $6.5 million ($12 million for FAR 13.500(e)) limit for the test program for commercial items?
Is this an oversight or am I missing a valid reason?
After unsuccessfully attempting to consult with FAR policy officials, a colleague and I concluded that those higher approval thresholds (above $12 million) at FAR 13.501 are in fact not applicable to the actions that would occur under the authority of FAR Subpart 13.5 and don't need to be in that section of the FAR. It should be noted that those same thresholds were carried over from FAR 6.304 and may apply to acquisitions under the Test Program 13.5, but only if they are for sole-source or brand-name items. However, in any case they are not applicable to acquisitions over $6.5 million/$12 million, which cannot be made under the authority of FAR 13.5.
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