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    What year money do use for the FY22 POP start dates; FY21 or FY22 since they will be in the base year of the new contract?


    The central concept of the Bona Fide Needs Rule is that appropriated funds may be used only for a requirement that represents the bona fide need of the requiring activity arising during the period of availability of the funds to be used for the acquisition. In other words, the bona fide need is determined by when the government actually requires the supplies or services being acquired. The scenario you present indicates that (up to) 11 contracts won’t be required until FY22 because current contracts are providing service coverage until then. Based on that assessment, FY22 funds would be appropriate for the 11 contracts that will have POPs in FY22.

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