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Overview

This section prescribes the mandatory inclusion of FAR clause 52.222-54, Employment Eligibility Verification (E-Verify), in federal solicitations and contracts exceeding $150,000, unless specific exemptions apply. It serves as the regulatory trigger for enforcing E-Verify requirements on federal contractors and subcontractors.

Key Rules

  • Threshold: The clause is required for all solicitations and contracts valued above $150,000.
  • Location Exemption: Contracts are exempt if the work is performed entirely outside of the United States.
  • Duration Exemption: Contracts with a period of performance shorter than 120 days are exempt.
  • COTS Exemption: Commercially available off-the-shelf (COTS) items are exempt, including:
    • Items with only minor modifications.
    • Items that would be COTS except for being shipped as bulk cargo.
  • Commercial Services Exemption: Services are exempt if they are part of a COTS purchase, performed by the COTS provider, and are services normally provided for that item.

Practical Implications

  • Compliance Burden: Contractors winning service or construction contracts over $150,000 must be prepared to enroll in and use the E-Verify system for all new hires and employees assigned to the contract.
  • Market Research Criticality: Contracting Officers must accurately categorize acquisitions; misclassifying a product as "Commercial" rather than "COTS" can inadvertently trigger E-Verify requirements that may deter some commercial vendors from bidding.

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