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  • Question

    What is the problem with this type of contracting?


    Answer

    Well, among other things, it violates Chapter 1 of Title 48 of the Code of Federal Regulations. See FAR 13.002(c)(2).

    I normally do not like to cut and paste chunks or sections of the FAR in AAP responses... but I will make a rare exception in this case.

    "Do not break down requirements aggregating more than the simplified acquisition threshold (or for commercial products and commercial services, the threshold in subpart 13.5) or the micro-purchase threshold into several purchases that are less than the applicable threshold merely to-

            (i) Permit use of simplified acquisition procedures; or

           (ii) Avoid any requirement that applies to purchases exceeding the micro-purchase threshold."

    Bold was added for emphasis. Since I do not know the dollar amount of your contract... I do not know if is (i) or (ii) that your agency violated.

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