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  • Question

    This contract has a Primary CLIN for the purpose of paying the contractor to keep a critical manufacturing process availble for use (non-IDIQ, CPFF). It also has a CLIN for ordering production parts from that process (IDIQ, FFP) and 2 For other kinds of technical services (IDIQ, CPFF). What is the correct letter to use in position 9 of the PIIN? DFARS 204.7003 appears to rule out "C", but does using "D" make all CLINs operate as IDIQ by default?


    Answer

    You are correct that DFARS 204.7003 "Basic PIN" rules out use of "C" as follows:  "C" = Contracts of all types except indefinite delivery contracts, sales contracts, and contracts placed with or through other Government departments or agencies or against contracts placed by such departments or agencies outside the DoD. Do not use this code for contracts or agreements with provisions for orders or calls.
     
    In reviewing the DFARS 204.7003, I would offer my Contracting Officer a strategy to use the "D" - Indefinite Delivery contracts in the 9th position of your PIIN. The use of "D" doesn't make all Contract Line Item Numbers (CLINs) operate as an IDIQ contract by default.

    You must create your CPFF, FFP, and Indefinite Delivery CLINs and reference them to their respective clauses that should be included into your contract.  FAR 16.102(b) "Policies" provides you the authority to pursue this strategy.
    FAR 16.102 -- Policies.
    (a) Contracts resulting from sealed bidding shall be firm-fixed-price contracts or fixed-price contracts with economic price adjustment.
    (b) Contracts negotiated under Part 15 may be of any type or combination of types that will promote the Government’s interest, except as restricted in this part (see 10 U.S.C. 2306(a) and 41 U.S.C. 254(a)). Contract types not described in this regulation shall not be used, except as a deviation under Subpart 1.4.

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