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    I have a requirement for the Development of Educational Courses and it consists of a Labor Hour CLIN. This is a renewal and is currently in the 8(a) program. There is one developmental CLIN of this contract where the hours cannot be projected precisely. The customer stated they can project the hours needed into 3 different CLINs (3-month, 6-month, & 9-month CLINs). I have 2 questions. Is it possible to keep this requirement within the 8(a) program and do a Sole Source IDIQ and just project the Labor Hour CLIN over 3 different FFP time periods? And would this be the best Acquisition Strategy to award this requirement?


    I assume the anticipated total value of the contract, including options, will notexceed $7 million for acquisitions assigned manufacturing North American Industry Classification System (NAICS) codes and $4.5 million for all other acquisitions.

    Why is the company unable to project the costs?

    Some things to consider:

    19.804-4 Repetitive acquisitions.

    In order for repetitive acquisitions to be awarded through the 8(a) program, there must be separate offers and acceptances. This allows the SBA to determine-

          (a) Whether the requirement should be a competitive 8(a) award;

          (b) A nominated 8(a) participant's eligibility, and whether or not it is the same 8(a) participant that performed the previous contract;

          (c) The effect that contract award would have on the equitable distribution of 8(a) contracts; and

          (d) Whether the requirement should continue under the 8(a) program.

    19.809-2 Limitations on subcontracting and nonmanufacturer rule.


    (a) Limitations on subcontracting. To be awarded a contract or order under the 8(a) program, the 8(a) participant is required to perform—

               (1) For services (except construction), at least 50 percent of the cost incurred for personnel with its own employees;

               (2) For supplies or products (other than a procurement from a nonmanufacturer of such supplies or products), at least 50 percent of the cost of manufacturing the supplies or products (not including the cost of materials);

    Have you talked with your SBA PCR?  I also recommend recahing out to your SBA District Office at

    You can get information at


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