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  • Question

    Is it required to have a document to determine the contractor's responsibility for GSA (non-DoD contract)/CHESS, AFWAY(DoD contracts) etc to follow FAR 9.104-1?


    Answer

    No, an additional responsibility determination is not required on orders created from an existing IDIQ contract.  FAR 38.101 summarizes the benefits of the Federal Supply Schedule program and paragraph (e) specifically states that GSA is responsible for complying with all applicable statutory and regulatory requirements.  In other words, the regulatory requirement for a responsibility determination was satisfied by the contracting office responsible for awarding the base IDIQ contract.  The Government Accountability Office's decision, B-296493.6, Advanced Technology Systems, Inc., October 6, 2006, supports this interpretation of the FAR as well.

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