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  • Question

    Is a separate Limited Source Justification or Sole Source Justification required in addition to the D&F? Or is the Economy Act D&F sufficient?


    Answer

    1.  Per review of FAR 17.5, DFARS 217.5, and the DFARS PGI 217.5, there is not a requirement to include a separate justification for other than full and open competition with this D&F.
    In addition to the D&F requirements which you included above, FAR 17.503(d)(3)(ii) indicates the servicing office (the buying office who will be making purchases for you pursuant to the Economy Act) is responsible for "complying fully with the competition requirements of part 6 (see 6.002)."
     
    2.  The same reference also indicates a process if they buying office is not subject to the Federal Acquisition Regulation.  In that case, you "shall verify that contracts utilized to meet its requirements contain provisions protecting the Government from inappropriate charges (for example, provisions mandated for FAR agencies by part 31), and that adequate contract administration will be provided."
     
     3.  Though a separate document is not required, recommend this D&F include evidence that you verified the buying office was aware of its responsibility to comply with appropriate competition requirements. 

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