When a contract that was awarded using FAR Part 13 has a modification that is valued over SAT, is a PNM required?
The following response is based solely on the question and background information provided. As we do not have all the facts particular to your situation, we highly recommend you consult, as applicable, your contracting officer and/or Legal Office for further guidance.
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"FAR 13.501(b) Contract file documentation. The contract file must include -- ....
(3) An explanation, tailored to the size and complexity of the acquisition, of the basis for the contract award decision..."
If the Simplified Acquisition Award Document referenced in the Question Background adequately addressees FAR 13.501(b)(3) then a PNM should not be necessary.