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    The information on Bona Fide Need / Color of Money is limited when it comes to this type of action. Side note add a DUA class for this stuff. *See the funding types and years below. I believe that these funds may not be able to be moved to fund the new action under CLIN 10 due to this CLIN would be for a new purpose. Those funds are beyond the period of availability. They were obligated appropriately on CLIN 3, but this would be a new purpose for them on CLIN 10. Please confirm or deny my interpretation. *Type of Fund(s) on CLIN 3: 2018 2019 2040 RDT&E (2 Yr) 2019 2021 2035 OPA (3 Yr)


    Answer

    Your question revolves around moving funds between CLINs on an IDIQ.  I am going to make an assumption that the funds on CLIN 3 are now expired, if the Appropriation is in the Expired phase it is not available to be obligated for a new effort.  Since IDIQ contracts are normally obligated at the DO level, then I believe this would be a purpose statue violation as well as a Bona Fide Need violation.  From the limited information and description you provided, not only is the money on different CLINs, but the intent is to use for a different, unrelated task which would be the Purpose Statute violation.

    I strongly suggest that you contact your local Comptroller/funds certifier and/or Legal Office to discuss this situation and receive additional guidance.

     

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