Is an RSCA form (May 2017 version 2) required for Foreign Military Sales? On page two of the form paragraph 4 it lists the exemptions for all service contracts and FMS requirements are not one of the exemptions. However, on page two paragraph 3 it states that "The Form is required and must be completed in the following circumstances: 1. before new solicitations are issued or contracts are awarded; 2. Before contracts are modified; 3. When each task order/delivery order is issued; 4. When funds are added; 5. When Army funds are being used to buy contractor labor, regardless of which organization is awarding or administering the contract; 6. When Army is the requiring activity, or is the executive agent for the mission/organization requiring the services; 7. When Army funds are being transferred to contracts outside the DoD.
You are correct, there are seveal things that are no longer exempt from completing the RSCA Form (May 2017, v2.0). Foreign Military Sales is NO LONGER and exception as you have noted in your question. The May version you referenced has rendered all previous versions obsolete.
However, according to the May 2017 Version 2 form itself - if you go to page 2, item #2, it prescribes that. "The most current version of the Form must be used and can be found at: http://www.asamra.army.mil/scra/documents/RSCA%20Version%202.0.pdf. When you go to that link is shows the Jan 2017 version 2.0 form. Additionally, the AFARS Subpart 5107.503(e) points you to the May 2017 form with the incorrect link on it. It is not possible for us at Ask a Professor, to determine the Army's meaning for this challenge.
Due to the incongruencies between the newest version of the RSCA FORM and the one reference on the form itself, this question would need to be addressed to the Army office responsible for the Form.