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    Can construction modification deductions be converted to fund construction modification increases by shuffling the funds around on paper PNM only as apposed to entering each change into PD2? Would you need to touch the PD2 computer, other than to change the SOW, in a mathematical modification wash gained from mod increases and decreases? In another scenario, outside a mathematical wash situation, would you only touch PD2 once in order to reflect the difference in all your new mod deductions and new mod additions should they not mathematically equate to a zero change in price but equate to a small reduction in price of contract? In short, can you take complete control of the existing contract funds yourself if you are in a situation where multiple MODS equate to a deduction or a wash. What procedures should be followed in PD2?


    Answer

    This response is based on the information provided.  We suggest you discuss with your contracting team, program manager and/or legal department as appropriate. 
     
    You did not address the value of these actions.  DoD requires certification IAW the clause at 252.243-7002.  So, if your subtractions are valued at $130K and your additions are valued at $130K you have an absolute value of $260K (greater than SAT).
    More importantly will these changes affect CLIN value(s)?  is the money being moved, of the same type (color) and year?  Depending on the phase of the Appropriation - Current, Expired or Canceled - and the scope of work being addressed (in or out of scope) will also drive the ability to make the changes you referenced.  If the funds are expired, then the funds are not available for new obligations so if the new work is out of scope then you could not use expired funds for that effort.  Will the contract in the system reflect what the contract actually is after the changes are made?
    If the contract is being changed in a material manner, it should be reflected with accurate modifications.

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