Purchases under BPAs
Purchases under BPAs must comply with legal thresholds, maintain competition, and be properly documented to ensure accountability and regulatory compliance.
Overview
FAR 13.303-5 outlines the procedures and requirements for making purchases under Blanket Purchase Agreements (BPAs). It specifies the conditions under which BPAs may be used, purchase thresholds, competition requirements, and documentation standards. The section ensures that purchases made under BPAs comply with legal and regulatory frameworks, maintain competition, and are properly documented for accountability.
Key Rules
- Authorized Use Only
- BPAs can only be used for purchases that are otherwise authorized by law or regulation.
- Purchase Thresholds
- Individual purchases under BPAs generally cannot exceed the simplified acquisition threshold, with exceptions for certain commercial acquisitions and specific authorities that allow higher limits.
- Competition and Set-Asides
- The existence of a BPA does not justify sole-source purchases or avoidance of small business set-asides; competition and set-aside requirements still apply to each order.
- Ensuring Competition
- If there are not enough BPAs to ensure competition for purchases above the micro-purchase threshold, contracting officers must solicit other sources and consider establishing additional BPAs.
- Documentation Requirements
- Documentation should be limited to essential information, with electronic or oral methods preferred. Paper documentation is only necessary when required for clarity or agreement. Essential purchase details must be recorded, and proper receipt and acceptance must be documented, especially if administration is assigned to another activity.
Responsibilities
- Contracting Officers: Ensure purchases comply with thresholds, competition, and documentation requirements; solicit additional sources and establish more BPAs if needed.
- Contractors: Comply with BPA terms and provide necessary documentation for receipt and acceptance.
- Agencies: Oversee compliance with competition, set-aside, and documentation requirements.
Practical Implications
This section ensures that BPAs are used appropriately, purchases remain within legal thresholds, competition is maintained, and documentation is sufficient for audit and accountability. Contractors and contracting officers must be vigilant about thresholds, competition, and proper record-keeping to avoid compliance issues.
