Is a Competitive Range Determination required prior to entering into discussions under FAR Part 13 procedures?
You are correct, in accordance with FAR 13.106-2(b)(3), establishing a competitive range is not required. However, establishing a competitive range and entering into discussions are not prohibited if the contracting officer believes these procedures are necessary for a particular procurement, including Simplified Acquisitions under FAR part 13.
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Given that FAR clause 52.212-1 was included in your solicitation, this clause "...reserves the right to conduct discussions if later determined by the Contracting Officer to be necessary."
As we do not have access to the solicitation and other details of this procurement, we recommend consulting with the Contracting Officer and Legal, as needed.