April 18, 2005

Department of the Interior Acquisition Policy Release (DIAPR) 2005-02

SUBJECT: Class Deviation from the Federal Acquisition Regulation (FAR) 53.212, 53.213-(a), 53.213(f), 53.236-1(e), Forms

1. Purpose:

The purpose of this policy release is to issue a class deviation from the revised Form use requirements at FAR 53.212, 53.213-(a), 53.213(f), 53.236-1(e) as included in Federal Acquisition Circular (FAC) 2005-02, March 23, 2005.

2. Effective Date:

Effective upon issuance.

3. Expiration:

This policy release shall remain in effect for each bureau until such time as that bureau transitions to the new contract writing system under FBMS.

4. Background and Explanation:

On March 23, 2005, FAC 2005-02 was issued amending Standard Form (SF) 1449, Solicitation/Contract/Order for Commercial items, SF 1447, Solicitation/Contract, and Optional Form (OF) 347, Order for Supplies or Services. All three forms were changed to add a check box for Service-Disabled Veteran-Owned Small Businesses (SDVOSB).
The Department of the Interior (DOI) is transitioning from one contract writing system (IDEAS) to another (PRISM) with the advent of DOI’s Financial Business Management System (FBMS). This transition will be implemented by bureaus, in phases, over the next two years. The changes to the Standard Forms referenced in FAC 2005-02 are expected to be included in the new contract writing system. The IDEAS contract writing system, however, would have to be modified in order to accommodate these changes. Providing funding to enhance a software system that is scheduled to be replaced in the short term is not fiscally prudent. In addition, the continued use of these forms as they appeared prior to the March 2005 revisions, in no way affects FPDS-NG reporting of SDVOSB actions or the way these actions are solicited and awarded. I have, therefore, in accordance with FAR 1.404, consulted with the Chairman, Civilian Agency Acquisition Council, regarding issuance of a class deviation.

5. Action Required:

In accordance with FAR 1.404, I hereby authorize a class deviation from the requirements at FAR 53.212, 53.213-(a), 53.213(f), 53.236-1(e) for all DOI acquisition personnel using the IDEAS contract writing system. IDEAS users should use the forms as they appeared prior to the March 2005 revisions.
Pursuant to DIAR 1401.404, class deviations, a copy of this class deviation shall be referenced in the contract file.

6. Additional Information:

If you have questions about this matter, please contact Kate Oliver by phone at (202) 208-3345.

/ signed Debra E. Sonderman, Director
Office of Acquisition and Property Management