Do I need a J&A to increase and decrease CLIN ceilings? One CLIN is decreasing by 833% one is increasing by 233%. Then the options will be funded as they are exercised. The overall value of the contract is decreasing.
This response is based on the information provided. We suggest you discuss with your contracting team, program manager and/or legal department as appropriate.
We believe you are correct to document the actions you are taking. If the contracting officer was incrementally funding a firmed fixed-price contract, that was likely incorrect and, without knowing if there are other circumstances, potentially anti-deficient.
Your legal advice was also correct. We use a J&A to support doing other than full and open competition. But you need to have a determination and findings in the record, particularly given the circumstance you are amending.