Should Engineering Change Proposals (ECPs), totaling hundreds of millions of dollars in costs, be used to improve/modernize an existing major weapon system?
Does regulatory guidance exist containing purpose, parameters, and boundaries for ECP use?
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Both the requirements of the Competition in Contracting Act and FAR Part 6 would need to be met. The general rule is that if the expansion of the project outside of what a reasonable offeror would have contemplated when preparing their original proposal then it is a cardinal change and not allowed.
However, there are a lot of "Ifs" with a great deal of room for interpretation. Strongly suggest conferring with the contracting commands legal office for a determination as to legality.