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    I and many others have always been of the view that after the notification within 30 days of initial award of a subcontract that any future change orders to that original award would not require a follow-up notification. This seems reasonable since the original notification puts the subcontractor under the purview of DCMA for CAS and the oversight that comes with that. Further, the clause merely states, 'Within 30 days after award of the subcontract, submit the following information to the Contractor's CFAO' Others believe notification is required when adding new work. Question: Is a second notification required for a modification that adds new work? If so, is it only if the modification trips the CAS threshold?


    Answer

    This response is based on the information provided.  We suggest you discuss with your CFAO, contracting team, program manager and/or legal department as appropriate. 
     
    We assume the modification for new work is within scope of the original contract.  FAR 52.230-6(l)(3) requires notification  within 30 days of a particular set of data to the Contractor's CFAO.  This data includes the subcontractor's name, subcontract number, dollar amount, date of award, and name of contractor making the award.
     
    FAR clause 52.230-6 states the following:
    ....
    "(l) For all subcontracts subject to the clauses at FAR 52.230-2, 52.230-3, 52.230-4, or 52.230-5
      (1) So state in the body of the subcontract, in the letter of award, or in both (do not use self-deleting clauses);
      (2) Include the substance of this clause in all negotiated subcontracts; and
      (3) Within 30 days after award of the subcontract, submit the following information to the Contractor's CFAO:
      (i) Subcontractor's name and subcontract number.
      (ii) Dollar amount and date of award.
      (iii) Name of Contractor making the award."
     
    The next paragraph FAR 52.230-6(m) requires notification to the CFAO for any adjustment required to subcontracts under a contract containing the clause FAR 52.230-6.  If the modification would alter any of the data provided to the CFAO as required  under FAR 52.230-6(l)(3) - i.e. dollar amount of subcontract - that would be an adjustment to the subcontract and would require written notice to the CFAO.
     
    FAR clause 52.230-6 states the following:
    "....
    (m) Notify the CFAO in writing of any adjustments required to subcontracts under this contract and agree to an adjustment to this contract price or estimated cost and fee. The Contractor shall—
      (1) Provide this notice within 30 days after the Contractor receives the proposed subcontract adjustments; and
      (2) Include a proposal for adjusting the higher-tier subcontract or the contract appropriately."

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