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At Last! Proposed Amendments to the FAR Reflecting Increased MPT, SAT and TINA Thresholds

October 10, 2019

On October 2, 2019, DoD, GSA and NASA issued two proposed rules to amend the FAR to implement various sections of the NDAA for FYs 2017 and 2018. Specifically:

  • Modifications to Cost or Pricing Data Reporting Requirements (FAR Case 2018-005) implements section 811 of the NDAA for FY 2018 to increase the threshold for requesting certified cost or pricing data from $750,000 to $2 million for contracts entered into after June 30, 2018. In the case of a change or modification made to a prime contract that was entered into before July 1, 2018, the threshold for obtaining certified cost or pricing data remains $750,000, with one exception: upon the request of a contractor that was required to submit certified cost or pricing data in connection with a prime contract entered into before July 1, 2018, the CO shall modify the contract without requiring consideration to reflect a $2 million threshold for obtaining certified cost or pricing data from subcontractors.
  • Increased Micro-Purchase and Simplified Acquisition Thresholds (FAR Case 2018-004) implements section 217(b) of the NDAA for FY 2017 and sections 805, 806, and 1702((a) of the NDAA for FY 2018. The proposed rule: (i) increases the MPT from $3,500 to $10,000; (ii) adds an exception to the MPT for acquisitions from institutions of higher education or related or affiliated nonprofit entities, or from nonprofit research organizations or independent research institutes, and sets the MPT for such entities at $10,000 or a higher amount as determined appropriate by the head of the agency and consistent with clean audit findings; (iii) increases the SAT to $250,000; and (iv) replaces specific dollar thresholds with the terms “micro-purchase threshold” and “simplified acquisition threshold.”

Comments to both proposed rules are due on or before December 2, 2019.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Nicole Owren-Wiest
Partner – Washington, D.C.
Phone: +1.202.624.2863
Charles Baek
Counsel – Washington, D.C.
Phone: +1.202.624.2894
Catherine O. Shames
Associate – Washington, D.C.
Phone: +1.202.688.3446