Is the intent of the DFARS $20M threshold to be applied to total contract value or instant actions (task orders)?
Reference DODi 5000.02 CHG 3 dtd 08/10/2017, Enclosure 1 table 8 "Additional Information": "...For indefinite delivery, indefinite quantity (IDIQ) contracts, inclusion of EVM requirements is based on the estimated ceiling of the total IDIQ contract, and then is applied to the individual task/delivery orders, or group(s) of related task/delivery orders, that meet or are expected to meet the conditions of contract type, value, duration, and work scope. The EVM requirements should be placed on the base IDIQ contract and applied to the task/delivery orders, or group(s) of related task/delivery orders. “Related” refers to dependent efforts that can be measured and scheduled across task/delivery orders..."
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The rationale for placing EVM on the base contract is so that EVM may be flowed down to Task Orders issued under that base contract. In your case, Task Orders awarded as pure Level of Effort (LOE) Task Orders would not meet the "discrete" qualifier for the nature of work to be objectively planned and work progress objectively measured throughout the period of performance of the Task Order.