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    What document defines the threshold as $1.5 million and duration greater than six months? Is it possibly FAR 4.1004 (Subline items may be used to facilitate tracking of performance, deliverables, payment, and contract funds accounting or for other management purposes. Subline items may be either deliverable or informational.) is the source? Although that would not apply to Other Transactions (OTs), since they are not governed by the FAR (FAR 4.601 Contract action does not include grants, cooperative agreements, other transactions, real property leases, requisitions from Federal stock, training authorizations, or other non-FAR based transactions.). Is there some U.S. Code or regulation that is the source of this requirement? Can a form (DD Form 1586) and a DID (DI-MGMT-81468) really be the source for a requirement? The statement on the same web page, "The CFSR requirement will not be applied to firm fixed price contracts (as defined in FAR 16.202) unless unusual circumstances require specific funding visibility." FAR 16.202 does reference a regulation, as indicated in the following statement in 16.202-1, "It provides maximum incentive for the contractor to control costs and perform effectively and imposes a minimum administrative burden upon the contracting parties." Again it might not be applicable to OT


    Answer

    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 found your answer in the CPRG Volume 4 Chapter 4.1 which states:  "The program manager should obtain a CFSR (DD Form 1586) on contracts over 6 months in duration. The CFSR has no specific application thresholds; however, the program manager should carefully evaluate application to contracts valued at less than $1.5 million (in then-year dollars)."

    We believe each program determines a dollar threshold based on the complexity and duration of the program and a need to have greater insight to expenditures.  Your service/agency (Space Force in your case) may have additional threshold guidance.  The CPRG also has the FFP info from the FAR.  The CPRG is accessible on line.

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