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    If acting SES is no longer in charge can they continue to sign RSCA under $250K or can the requesting Activity have O-6/GS-15 sign/approve RSCA?


    A response from the question submitter revealed RSCA did in fact mean the "Request for Service Contract" form. Reminder to all AAP submitters, please spell out acronyms unless you are 100% certain it is widely used throughout DoD and in the acquisition community.

    This is a great question because there is some vagueness on who must/may approve the form at the dollar value mentioned.

    Bottom Line Up Front: Yes, see the RSCA form itself (May 2017 version 2) Instructions; where at paragraph 5 (page 3) it states “For a contract with a total value below the Simplified Acquisition Threshold (SAT) (including all supplies and services, as well as all the option years combined), the accountable GO or SES in a requiring activity may delegate signature authority to a GS-15/O-6.

    Research Process:

    In researching AFARS 5137.503 we see that “Army Regulation 70-13, Management and Oversight of Service Contracts, chapter 2, implements the responsibilities set forth in FAR 37.503(a), (b) and (d). See 5107.5 for implementation of FAR 37.503(c) and DFARS 237.503.”

    Unfortunately, neither AFARS 5137.590, AFARS Appendix GG, or AR 70-13 specify who must/may approve the RSCA for actions below the simplified acquisition threshold (SAT).

    As a result, we could rely on the FAR conventions, specifically FAR 1.108(b) Delegation of authority. Each authority is delegable unless specifically stated otherwise (bold italics added for emphasis). Additionally, the table in AFARS Appendix GG indicates that all approval authorities for AFARS 5137 actions (which would include approving the RSCA) are delegable.

    However, section 2-9 Management controls of AR 70-13 makes no mention of acquisitions below the SAT. AR 70-13 section 2-9(a) has this language "... however, HQDA principals and senior commanders may delegate the responsibility to the accountable authority at the general officer or senior executive service level." Indicating that's the lowest level, but then 2-9(c)(4) and (d)(4) both say the Director of Contracting or the Program Manager; which I'm sure in some instances is NOT a GO or SES.

    Finally, as mentioned above, the Form itself provides the authority.

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