Modify Regs to Address CICA Difficulties Relating To IDIQ Orders

For IDIQ orders for services (including construction) the true competition takes place at the task order level. The unit prices established at the "umbrella" contract level are essentially meaningless to knowing what the actual cost of work is, yet CICA requires that we establish binding prices. This is particularly problematic for services, where the quantities of units can vary greatly contractor to contract, and it's even more problematic for complex services like construction, that can have literally hundreds (if not more) of items, including labor hours and materials, that make up an order. IDIQ contracts for construction are critically necessary in order to quickly provide construction services, especially in light of budgets that don't get issued until late in a fiscal year. Additionally, given security clearance requirements, it speeds project delivery to deal with the same small group of contractors repeatedly. Finally, it's beneficial when contractors are familiar with specific buildings and the unique issues that surround each one.

All these issues support the need for making it easier to establish IDIQ procedures which recognize that for services unit prices are not indicative of final prices, and competition truly takes place at the task order level.