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  • Question

    If firms have a corporate headquarters office approval from the OFCCP is it necessary to have a separate registration for different locations of the same firm? All the work will be performed in the United States western region.


    Answer

    Your reading of FAR 22.805(a)(4)(1) is accurate; but your reference to FAR 52.222-24 indicates that:

    "If a contract in the amount of $10 million or more will result from this solicitation, the prospective Contractor and its known first-tier subcontractors with anticipated subcontracts of $10 million or more shall be subject to a preaward compliance evaluation by the Office of Federal Contract Compliance Programs (OFCCP), unless, within the preceding 24 months, OFCCP has conducted an evaluation and found the prospective Contractor and subcontractors to be in compliance with Executive Order 11246."

    This suggests that the first tier subs must be evaluated.  This is consistent with the notice on the Pre-Award Registry that:

    "This system provides information only for the specific Contractor Facility(s) requested. It does not provide information on the Parent Organization or other facility locations that have not been reviewed within the past two years. If a given facility is found to be "In Compliance", this does not imply that other sibling facilities under the same parent organization received the same favorable finding."

    You may find more detailed guidance in USACE Acquisition Instructions (UAI) or in MACOM Contracting Management Review Guides.

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