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Does the FAR Online Representations and Certifications Application (ORCA) requirement apply to a Grantees proposal submission process?

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Does the FAR Online Representations and Certifications Application (ORCA) requirement apply to a Grantees proposal submission process?

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We received an email stating that beginning January 1, 2005 the FAR will require the use of ORCA in federal solicitations. We understand that the Best Practices Manual references FAR primarily as a guidance tool for Grantees. We want to confirm that this requirement does not apply to our procurement process.

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