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  • Question

    Is it ok to accept a MIPR DC with two lines for two separate contracts? Which guidance supports the answer.


    Answer

    While no specific guidance expressly prohibits multiple contracts on the same MIPR, one can infer from standard DD Form 448 (MIPR) instructions that the answer to the question is “no.” DFAR supplement PGI 253.208-1 instructions for block nine read, “Normally restrict a MIPR to one major end item, including its required spare parts, ground support equipment, and similar related items.  For other than major end items, limit MIPRs to items within a single Federal supply class when possible.”

    Note that MIRP section 14 captures Accounting Classification Reference Numbers (ACRN). If the sender uses the ACRN construct cited in DFAR Supplement PGI 204.7107 (under the Uniform Contract Line Item Numbering System), by definition the MIPR is limited to a single contract action because each ACRN is a separately identifiable line/subline under the same contract.

    Many organizations have developed local, fillable pdf versions of the DD Form 448, some that limit ACRNs to a single entry and some that force the sending activity to choose between citing the line of accounting as either direct or reimbursable; it offers no choice for a combination of the two.

    That said, many version of the MIPR expand the blocks, provide the sending activity sufficient space to have multiple combinations of entries and have detailed instructions to the receiving activity for most any combination of needs of the sending activity, e.g., multiple funding lines for multiple contracts, direction to cite direct or reimbursable.

    From a practical standpoint, providing funding for more than one contact on the same document can easily be a recipe for confusion.  It can be an administrative nuisance because neither funding stream is purely linear (links in a single chain); the document now splits from one path into two.  Since the receiving activity must formally accept the MIRP, it can easily ask the sending activity to separate the contract funding into separate documents, if only to support a clearer and cleaner audit trail

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