Assuming the service contract otherwise meets conditions in PGI 201.602-2 (d)(v)(A)(2) and (3); does a service contract under SAT fail the condition in PGI 201.602-2 (d)(v)(A)(1) ("awarded using simplified acquisition procedures") if it is awarded under parts that don't include Part 13? (i.e. GSA order, NASA SEWP, etc.). Or is a COR required, even in a simple service order in GSA at a value of $5K?
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The language in DFARS, PGI 201.602-2 (d)(v)(A) DOES require the strict interpretation that they only time you are exempt from assigning a COR is if all three conditions exist. In other words, you are required to assign a COR if using FSS, awarding off of a GWAC or other indefinite delivery contract.
The existing PGI and language included in DoDI 5000.72 was heavily influenced by Congress and the Panel on Contracting Integrity.
We have forwarded a request to DPAP/CPIC to consider changing the language. They have taken it under advisement. At this time I am unable to answer what their decision will be and/or if they will forward to the DARC.