Does the RSCA have to be modified to reflect the base plus four year options or can the received RSCA be used? Would the additional options be considered new work?
I want to emphasize that your legal is in a better position to offer you advice on your specific question. However, there does appear to be two separate issues that I can tell. The first issue is that these two recently contemplated options are unpriced. Given this, you should consider DFARS Subpart 217.74 - Undefinitized Contract Actions and the policy and procedures set for therein.
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The second issue involves the RSCA. Based on the facts you present, it would appear that you could argue that a revised RSCA would be appropriate because of the stated policy in the AFARS Part 5107. If there is some reason why your organization feels a revised RSCA is unnecessary, there is still the concern that GAO has repeatedly addressed in its annual report to Congress that government agencies are in the habit of not adequately documenting contract files. Therefore, it there is something that happened beyond the RSCA (such as the change from two to four options), this should be explained in the contract file adequately enough that a reader picking up the file would be aware why it happened, when it happened, what purpose that changes served, etc. To do so is simply good contract administration.