GAO was requested to comment on the proposed revisions to 41 C.F.R. subparts 1-4.11, 101-35 and 101-36. GAO believes that the revisions are sound and should provide for more effective and economical federal automatic data processing (ADP) support regarding obsolescence. However, the change under Federal Procurement Regulation 1-4.1104-1 and Federal Personnel Management Regulation (FPMR) 101-35.209-1 should be clarified regarding when a Delegation of Procurement Authority is not needed for an update acquisition action. Under FPMR 101-36.202, GAO believes that the conditions should be linked with an or condition and not an and, as contained in the proposed change.
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