Given an IDIQ doesn't have any funds attached to it, can a CO release an IDIQ with an aggregate value over their warrant authority? If there's not money attached, are they only providing a vehicle instead of an obligation of funds? Also, if a CO/CS is changing the ordering period under an IDIQ contract (no change in funding/cost), are they within their authority to do so, no matter their warrant level?
This response is based on the information provided. We suggest you discuss with your contracting team, program manager and/or legal department as appropriate.
Contracting officers can only legally act within the boundaries of their authority. The value of a contract is determined by the amount the government can be exposed to. So, if a contracting officer's warrant is for $5M and the initial award of an IDIQ for example is $750,000 yet the maximum value of the IDIQ could go to $10M, the contracting officer does not have authority to execute.
"FAR 1.108(c) Dollar Thresholds Unless otherwise specified, a specific dollar threshold for the purpose of applicability is the final anticipated dollar value of the action, including the dollar value of all options. If the action establishes a maximum quantity of supplies or services to be acquired or establishes a ceiling price or establishes the final price to be based on future events, the final anticipated dollar value must be the highest final priced alternative to the Government, including the dollar value of all options."