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Below are some potential avenues to pursue with regard to your program. The main question is since you say in your official request that your program is NOT a Program of Record, then why do you believe that it requires an Acquisition Strategy? Acquisition Strategies are required for Programs of Record. Depending upon the dollar amount of your program, the rules for applicability to either Simplified Acquisition Program or Middle Tier Acquisition Program may be more appropriate. Below are links to information regarding both of these pathways.
FAR Part 13 (at the links below) provides the dollar thresholds for potential applicability of programs under Simplified Acquisition Programs. It is specifically for the purchase of Commercial Items. The size of your program; specifically the dollar thresholds may determine the path the questioner may need to follow.
https://www.acquisition.gov/content/part-13-simplified-acquisition-procedures
https://aaf.dau.edu/aaf/contracting-cone/simplified-acquisition-far-part-13/
Middle Tier Acquisition: Rapid Fielding may present a viable alternative for pursuing the quantities of COTS items you are seeking to purchase. Links to the Middle Tier Of Acquisition (MTA) on the DAU website are provided below, as a potential viable alternative if Simplified Acquisition Program procedures are not applicable to the strategy you wish to follow. Follow the link under the Rapid Fielding Pathway.
https://aaf.dau.edu/
https://aaf.dau.edu/aaf/mta/
https://aaf.dau.edu/aaf/mta/fielding/
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Please note that you should expect to receive a response from our team, regarding your inquiry, within 2 business days.