Can procurement funds be used to conduct PQT, or is there some statute, regulation or policy that constrains PQT to being done only with RDT&E funds? Has policy recently changed in this regard?
Procurement funds are used to buy personal property end items not in development. The issue in situations such as these often centers on terminology and what definition is agreed upon for the selected terminology. If the chosen language describing the testing lends itself to a research and development (R&D) interpretation; it would be most appropriate to use R&D funding.
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FAR subpart 9.3 – First Article Testing and Approval, offers language which clearly lends itself to a ‘production’ interpretation. Procurement funding is most appropriate for buying items in production. This scenario is presented as a commercial item acquisition (FAR part 12). FAR 9.304 offers that, “normally,” First Article Testing (FAT) would not be necessary by virtue of the item being commercial. FAR 9.303(b) describes conditions under which the government may want to conduct FAT even with a commercial item.
Work with your acquisition team members to select language that best aligns with what you are buying. Utilizing authoritatively defined language, as suggested here, can help in reaching quick consensus over acquisition terminology and its interpretation.