If we award this task order on 30 Nov 2017 with performance to begin on 01 Feb 2018, should the date in Block 3 (Call/Order Date) on the DD-1155 reflect the date of award (30 Nov 2017), or the date when performance is scheduled to begin (01 Feb 2018)?
The question presents a scenario impacting numerous other aspects of the contractual process, which could have possible inconsistencies, confusion, and/or contradictory information throughout the administration, documentation, performance, payment and overall management.
1. The date of the contractual vehicle is the actual date, including the signature of the contracting officer, of the contract action. This date also identifies when the funding is to be obligated. There are additional requirements per FAR Part 4 for reporting contract actions. Per DFARS PGI 204.606 Reporting Data, there are specific instructions for entering data in the Federal Procurement Data System, (among other instructions and requirements) which indicate the “Date Signed” data field represents the date the contracting officer signed or otherwise awarded the contract action. (DFARS PGI 204.602(3)(v)(A))
2. The period of performance or delivery/performance schedule has its own data field and is also associated with other aspects of the contract action. The ordering procedures at FAR 16.505(a)(7) states: Orders placed under indefinite-delivery contracts must contain the following information: (i) Date of order; (iv) Delivery or performance schedule; (vii) Accounting and appropriation data.
3. DFARS PGI 204.606 Reporting Data has instructions for specific data entries involving performance dates – when entered, completed, and other documentation associated with ordering requirements and contractor involvement.
4. DFARS PGI 253.213-70 Completion of DD Form 1155, Order for Supplies or Services, identifies criteria for use of the form, with its mandatory instructions. The instructions at paragraph (e) identifies the information for Block 3 Call/Order Date, which is different for required information in Block 19 (9) Delivery Date.
5. The question/scenario indicates performance to take place after the expiration of a contract action, which has a major impact on funding and concern for overall validity.
While these are just a few potential concerns/issues that could arise, review and weigh the overall effectiveness and efficiencies for the customer. If performance is outside the requirement and contractual arrangement, extensions or modifications, seek guidance and legal input for consideration of another best strategy for the additional requirement.