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    How should the cloud computing services be added to the contract? The COR originally anticipated added the services under the cost reimbursable ODC CLIN. Im apprehensive to do so since I dont think commercial cloud computing should be contracted under a cost reimbursable CLIN. However is it contractually and legally acceptable to purchase cloud computing under an ODC CLIN? Should I create a new subscription CLIN for the cloud computing services? The cloud computing requirement was originally documented in the PWS so maybe the monthly cloud computing service subscription should actually be a subcontract paid by the prime under the FFP Labor CLIN?


    Answer

    Since it was part of the initial requirement and clearly defined in the PWS (within scope), you may add the cloud services via contract modification. You may add a new CLIN for the cloud services subscription, but  check to see how was the cloud service (future) modification documented in the acquisition plan, and  you should also look at the contract to see how the prime accounted for this future modification in its proposal.  That should help you determine how to add the cloud services subscription.
     
    Normally, subscription services are paid before you use them as a fixed price, much like a magazine or cable bill.  Although this is easy, the problem often rises in overage data rate charges. Make certain you have accounted for this potential to avoid an unauthorized commitment.
     
    Always consult your contracting officer and your agency's legal counsel before proceeding. 

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