What a modification may change

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1. Changes the government can make alone

Under the Security Assistance Management Manual (SAMM), a modification makes administrative changes to a Foreign Military Sales (FMS) case. The changes must not alter the scope of the case, a line or a note (SAMM C6.7.3.1). The government can make these changes unilaterally, without the purchaser’s acceptance. Correspondence from the Defense Security Cooperation Agency (DSCA) or the implementing agency (IA) can serve as the document of record. DSCA confirms that changes to government-provided articles and services are within scope during its case review, with the IA supplying supporting data. The difference between amendments and modifications is covered in amendments and modifications.

The manual’s table lists examples of allowable changes (SAMM C6.7.3.1.1). The examples cover money, descriptions and administrative codes, and two changes made at the purchaser’s request. The only exception allowing scope changes on a modification is a concurrent modification, which the manual treats separately (SAMM C6.7.3.1).

2. Money changes

Funding on a defined order line may go up or down to match actual or projected billing from over or under commitment (SAMM C6.7.3.1.1). It may also change when a case is reconciled at supply and services complete before closure (SAMM C6.7.3.1.1). Lines may be deleted only after the whole case is supply and services complete and ready for closure. The price on a blanket order line may change with actual billing. One example is an order placed on an estimate, where the price rose at a point when the quantity could no longer be cut. The IA must record the original and the increased price in case remarks. A decrease must not cut the line below the expected final billing.

Other money items are corrections (SAMM C6.7.3.1.1). A modification can correct accessorial charges, revise payment schedules and correct prices after a policy change such as a new administrative rate. It can add value added tax and similar international charges levied on the United States that a nationally funded case must pay. It can also add charges already incurred, such as storage, that the case must fund.

3. Descriptions and codes

For materiel supplied in units that is neither major defense equipment nor significant military equipment, the amount per unit may be added, updated or removed in the line description or note (SAMM C6.7.3.1.1). Ammunition boxes are the manual’s example. The number of months on a line can be changed for adverse events, such as pandemics, contracting or production delays, or conflict in the country, because these do not change scope.

Line descriptions and their notes may be edited where scope, capability and classification stay the same, for example to correct nomenclature (SAMM C6.7.3.1.1). Changes to notes on enhanced end use monitoring must be coordinated with DSCA’s end use monitoring office before the case goes to its case writing division. An inactive item code on the military articles and services list, for equipment that is not significant military equipment, may be replaced with an active one. Item codes for significant military equipment or major defense equipment, active or not, cannot be replaced by modification. Source codes, line managers, offer release codes and type of assistance codes can be revised, and typing errors fixed.

4. Two changes the purchaser asks for

Subject to the IA’s acceptance, a line can be switched from full and open competition to sole source by modification (SAMM C6.7.3.1.1). The request has to be made by the person who requested the offer or their replacement, or by someone known to have at least the signer’s authority. Sole source requests are covered in when a buyer names the supplier. On the purchaser’s written request, a modification can also add a repayable FMS credit or a Foreign Military Financing guarantee as a term of sale, with the matching change to the type of assistance code.

5. Lines carrying an older surcharge rate

Lines priced at an earlier administrative surcharge rate get extra scrutiny. On a modification, the IA must review them to confirm there is no change in scope (SAMM C6.7.3.1.1). Within-scope changes can be made on the existing line, but if a contracted line’s price changes, the IA checks with the contracting officer or the officer’s representative that the change is not about scope.

Amendments work the other way (SAMM C6.7.2.1.1). Where a line with an earlier rate has a change in scope, the added scope must go on a new line. Where there is no change in scope, changes may go on the existing line unless the price changes, in which case the same contracting check applies. Concurrent modifications follow the amendment pattern (SAMM C6.7.3.2.2.1).

6. Closure and placeholder lines

Price increases found after a case is supply and services complete are validated during final reconciliation (SAMM C6.7.3.1.3). If spending exceeds the ordered value, a modification or amendment is needed, and most such actions are handled by modification (SAMM C6.7.3.1.3.1). If spending stays within the ordered value, the case may close without either (SAMM C6.7.3.1.3.2).

Lines at a token value, such as $0, $1, $2 or $10, created only as placeholders or for tracking are not allowed (SAMM C6.7.6.2). A line that must stay at such a value for audit or transaction reasons needs an approved exception to policy. A case whose only line is at minimal value should go to closure. The manual lists exceptions that need no approval (SAMM C6.7.6.3). They include the Euro-North Atlantic Treaty Organization (NATO) Joint Jet Pilot Training Program, electronic combat software and hardware, excess defense article grants, and classified software whose development costs sit on other lines. Capacity building lines left at minimal value after unused funds moved to other priorities, lines carrying items redirected from another capacity building case, and minimal-value training lines kept for student accounting are also covered.

Key terms

Modification	A unilateral, within-scope administrative change to a case.
Supply and services complete	The stage after which a case moves toward reconciliation and closure.
Months	The months field on a line, which can change for adverse events without changing scope.
Previous administrative rate	An older surcharge rate kept on a line, which limits how it may change.
Minimal-dollar line	A token-value placeholder line, allowed only by exception.

Every statement above links to the document behind it. The full source list for this piece is on the sources page.

This page describes public United States government programs for general information. It is not legal, regulatory or procurement advice, and it does not address the facts of any particular case.

How Sentfore supports this

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