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    Is there a "blanket" or contract level approach that can be done for subcontract consent? For example, the contractor has a database/pool of potential consultants and SMEs, is it possible to do a subcontract consent for the company at a contract level so that these individual subcontract consents won't have to be accomplished for each applicable task order? Thanks


    Answer

    While the basic contract is CPFF, consultant services are often performed on a labor-hour/T&M or fixed-price basis. (The contract type for the task orders wasn't identified in the scenario.) If the individual task orders are fixed-price, do they exceed either $250,000 or 5% of the base contract estimated cost? Many task orders for consulting are less than at least one of those thresholds—

    FAR 44.201-1(b)  If the contractor does not have an approved purchasing system, consent to subcontract is required for cost-reimbursement, time-and-materials, labor-hour, or letter contracts, and also for unpriced actions (including unpriced modifications and unpriced delivery orders) under fixed-price contracts that exceed the simplified acquisition threshold, for--

        (1) Cost-reimbursement, time-and-materials, or labor-hour subcontracts; and

        (2) Fixed-price subcontracts that exceed-

             (i) For the Department of Defense, the Coast Guard, and the National Aeronautics and Space Administration, the greater of the simplified acquisition threshold or 5 percent of the total estimated cost of the contract (emphasis added).

    If no exception above applies and a small group of consultants routinely receives the task orders, any required approvals subsequent to the first one for each consultant could reference the first approval for each consultant. This could avoid the need for a detailed written approval for each and every task order repeatedly issued to the same consultant.

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