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    Can we use administrative costs such as the KO and PM's time as a duplicate cost the government would incur to create competition in AFARS 5153.303-5(5)(b)?


    After further clarification, a more detailed question is can administrative costs (like CO and OM) be counted as a cost the government would incur "to create competition" (preparing the RFI, solicitation etc) or are these costs (CO and PM) simply a cost of doing business for the government that should not be counted as a cost to create competition?

     The answer depends on what administrative efforts of the KO and PM you are considered as duplicate.  If your rationale is that by reviewing or evaluating multiple offers is duplicative, the answer is no.  That is their stated responsibility and is not duplicative.  One viewpoint is those actions would not be duplicative in that they have to be performed in order to comply with FAR Part 6 competition policies. 

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