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  • Question

    Can we process a Task Order that is funded with OPN funds for non-severable requirement?


    Answer

    Yes.  According to DoD 7000.14-R Financial Management Regulation, Volume 3, Chapter 8, parapraph 080304.B.2: "A service contract is non-severable or entire if performance of the service results in a single or unified outcome, product, or report that cannot be subdivided.  The performance period of a fixed price non-severable services contract may cross fiscal years, but must be fully funded in the initial fiscal year unless contract funding requirements exists set forth at DFARS 232.703-1(1)(ii).  Unless the period of performance is entirely within a single fiscal year (not the case here) or within the charged account's period of availability if funded using a multiyear appropriation (again, not the case here), non-severable services contracts may not be funded on an incremental basis unless Congress has authorized incremental funding.
     
    So, if this is truly a non-severable effort and Congress has not authorized incremental funding for this effort, then it must be fully funded in the year it is awarded.

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