Warrant is an unlimited option
November 21, Before answering, there are two issues to be addressed.
See FAR On to the question at hand: As Joel pointed out, the authority of the KO to contract is limited by the authority delegated to him or her. In my opinion, this argument is incorrect as it conflates the rules governing obligating funds with entering into a contract. FAR 1.
Unless otherwise specified, a specific dollar threshold for the purpose of applicability is the final anticipated dollar value of the action, including the dollar value of all options. If the action establishes a maximum quantity of supplies or services to be acquired or establishes a ceiling price or establishes the final price to be based on future events, the final anticipated dollar value must be the highest final priced alternative to the Government, including the dollar value of all options.
Now, it should be noted that the first sentence of FAR 1.
Therefore, the conventions associated with interpreting the Warrant is an unlimited option do not apply to interpreting the delegation of authority.
And, if an agency, as a matter of policy, expressly exempted authority delegations from what option FAR conventions, then I could support that interpretation.
First, the FAR expressly directs delegations of authority to state any limitations; therefore, the limitation is in fact a FAR threshold even if the specific dollar amount is not stated in the FAR.
Second, establishing different dollar values to the same contract would add unnecessary confusion by creating scenarios where a contracting officer who is held out to the public as having authority that does not exceed the SAT is awarding a contract that cannot even be awarded using FAR Part 13 simplified procedures.
Based on the above, absent agency regulations or supplements that state otherwise, a contracting officer subject to the sample delegation provided cannot award an IDIQ contract with a maximum amount that exceeds her authority.
Warrants Explained For Beginners - How Do Spac Warrants Work? How do you exercise / redeem warrants?
Link to post.