Hello! In a previous response, you said that "normally when there is an acq strategy...for...a task ordering contract there is no need for a separate acq strategy for each individual task order". Can you clarify what you mean by "normally"? In what circumstances would a separate acquisition strategy be required for a task order (outside of a TO against an IDIQ awarded by a different agency, per FAR 7.101 definition, that is)? It appears from the FAR's definition that only TOs on a different agency's IDIQ would be concerned.
Can you provide an actual regulation citation that I can give to my management that says the acquisition strategy approved for the IDIQ itself covers all task orders placed against it? The cites you responded with previously were for an entire subpart, or were for acq plan contents and thresholds. These do not say that TOs are covered by the existing IDIQ acq strategy.
I'd really appreciate your help, since preparing these for each and every TO wastes valuable time and resources (and our org doesn't seem to interpret the FAR as everyone else does).
Thanks so much!
No, I cannot. The Federal Acquisition Regulation (FAR) at FAR 7.102(a)) requires that “Agencies shall perform acquisition planning and conduct market research (see Part 10) for all acquisitions…” Please note is states “all acquisitions.” Then we move to FAR 7-103, Agency Head Responsibilities, where at subparagraphs d and e it requires:
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“The agency head or a designee shall prescribe procedures for --
(d) Establishing criteria and thresholds at which increasingly greater detail and formality in the planning process is required as the acquisition becomes more complex and costly, specifying those cases in which a written plan shall be prepared.
(e) Writing plans either on a systems basis, on an individual contract basis, or on an individual order basis, depending upon the acquisition. …”
Notice that subparagraph (e) allows for writing plans “…on an individual order basis, depending on the acquisition.” Therefore, your organization is within the FAR prescribed guidance when it requires a written acquisition plan for each individual task order (TO). There is much flexibility in establishing the circumstances for requiring written acquisition plans. For example, the DFARS 207103(d)(i) establishes dollar thresholds and other circumstances mandating a written plan. This situation continues as we look at individual agency requirements such as the Army under AFARS 5107.103(d)(i) and the Air Force under AFFARS 5307.104-92 for example.
It would appear that your challenge is convince your management to establish an appropriate threshold for written acquisition plans considering the value-added of preparing a written acquisition plan versus the amount of administrative effort required in creating such plans.