# MP5317.74 Undefinitized Contract Actions

#### Mandatory Procedure

MP5317.74
Undefinitized Contract Actions (UCAs)

[Revised February 14, 2011]

1. Policy.

a. UCAs should be used on an infrequent basis for clearly defined, urgent requirements and must be definitized within the established 180 day definitization schedule.

b. Contracting officers must only obligate funds consistent with the contractor’s spend plan for the undefinitized period and also stay within the maximum obligation amount allowed in DFARS 217.7404-4. Obligating funds in excess of the contractor’s spend plan encourages extended periods of performance prior to definitization.

2. Notification Requirements.

To comply with the requirements described in DFARS 217.7402, SCOs or the SCCOs at ASC, ESC, AAC, and SMC shall provide notification to SAF/AQCK, safaqck.workflow@pentagon.af.mil, 30 days prior to the issuance of any UCA for a foreign military sale or congressionally mandated long-lead procurement contract that does not adhere to the policies and procedures described in DFARS 217.74. The notification shall include detailed rationale to support the determination. Any applicable special access program action shall be forwarded, through secure program channels, to SAF/AQCS, who will coordinate the notification through SAF/AQC.

3. Proposal and Definitization Requirements
a. Contracting officers must comply with MP5315.4, Contract Pricing, for procedures on proposal kick-off and proposal walk-through meetings, proposal instructions, and requesting data/documentation after receipt of the proposal.

b. Undefinitized Contract Actions (UCA) approval authorities shall establish procedures for field offices to track all UCAs as defined in DFARS 217.7401(d) and DFARS 217.7402, to the maximum extent practicable.
c. For any UCA that falls more than 14 days behind its schedule at any point in the definitization process, the cognizant SCO/SCCO must review each such UCA monthly and provide the DAS(C) a status report identifying the remedial actions that have been or are being taken to get back on schedule no later than 5 business days after the end of the month. The report, in e-mail format, shall be sent to safaqck.workflow@pentagon.af.mil. Further, the DAS(C) may require the SCO/SCCO and any members of the definitization team to brief the appropriate HAF staff on the status of any UCA not definitized with 180 days of issuance. For any delays in the definitization schedule, contracting officers shall document the contract file with the justification to include the revised definitization milestone schedule.

4. Profit.

Contracting officers must comply with the Weighted Guidelines method at DFARS 215.404-71-3(d)(2) which indicates that, when costs have been incurred prior to definitization, generally the contract type risk should be regarded to be in the low end of the designated range. If a substantial portion of the costs have been incurred prior to definitization, the contracting officer may assign a value as low as 0 percent, regardless of contract type. AFMC maintains a web-based Weighted Guidelines program available at https://www.wgl.wpafb.af.mil/wgl/. This web-based tool provides the capability to address incurred costs in the profit analysis for UCAs. Contracting officers must use this tool throughout the UCA negotiation process to make adjustments based on costs incurred to the AF profit objective.

5. Plans and Reports

To comply with the semi-annual UCA reporting requirements described in DFARS 217.7405, SAF/AQCK will request all SCOs to submit their semi-annual UCA Management Reports for UCAs with an estimated value of more than $5M in the format described in DFARS PGI 217.7405(2)(ii) to SAF/AQCK, safaqck.workflow@pentagon.af.mil. SAF/AQCK will consolidate the UCA Reports and submit the consolidated report to OUSD (AT&L), Director, Defense Procurement and Acquisition Policy no later than April 30 and October 31 of each year.