DISA Gave Itself 37 Days

DISA's notice on Wednesday runs four sentences. One of them cites a FAR paragraph that, in the codified text, says something else entirely.

Here it is in full, from SAM.gov special notice 612674630, posted 10:36 Zulu on August 26:

"In accordance with (IAW) FAR 7.107-3(b), this serves as formal notification that the Government intends to solicit the Building Operation Support Contract and the Building Automation System Maintenance Contract into a single, combined procurement requirement moving forward. This has been determined necessary and justified IAW FAR 7.107-2. The justification will be included with the solicitation IAW 7.107-3(b)(2)."

No attachments. No response date.

NAICS 561210, PSC S216, place of performance Fort George G. Meade, contracting office DITCO-NCR, auto-archive September 2.

That is the entire public record of a decision that closes a small-business seat.

The Citation Is the Tell

Look up 7.107-3 in the codified FAR and you get Bundling. Its paragraph (b) is a single sentence telling the agency to quantify benefits through market research, and there is no (b)(2) under it.

The consolidation notice requirement sits two subsections further down, at 7.107-5(c).

So the cite reads wrong, unless DISA is working from the overhauled Part 7. It is.

The Revolutionary FAR Overhaul model text for Part 7 went to the Federal Register in June alongside Parts 6, 10, 18, 26, 37 and 41, and the deviation guide carries a July 28 update stamp. It rebuilds the section into three pieces: 7.107-1 General, 7.107-2 Policy, 7.107-3 Notifications. The new 7.107-3(b) is the public notice, and it does have a (b)(2). DISA cited it correctly. The codified FAR is the thing that no longer matches.

Now, the change underneath the renumbering is the part that should hold your attention.

The codified FAR runs consolidation and bundling on separate tracks: a 7.107-2 determination and a 7.107-5(c) notice for one, a 7.107-3 determination and a 7.107-5(d) notice for the other. Read the citation and you knew which species you were looking at. The overhaul merges them into one determination at 7.107-2 and one notice at 7.107-3(b), both worded as "consolidation or bundling."

So the notice no longer tells you which one this is. And under 7.107-3(b)(2) the determination that would tell you does not publish until the solicitation does.