Is a Certification and Disclosure Regarding Payments to Influence Certain Federal Transactions needed if a PO value increases, at any time, to greater than $150,000 as a result of a modification? If it is, is it based only on the value of the modification or the total/aggregate value of the awarded PO?
The FAR is not clear on this point, but the law the requirement is based on, 31 U.S.C. 1352
, states: "The prohibition...applies with respect to...the extension, continuation, renewal, amendment, or modification (my emphasis) of any Federal contract, grant, loan, or cooperative agreement." It would be prudent to require the certification and disclosure in the situation you describe.