Blanket purchase agreements (BPAs)
FAR 8.405-3 mandates competitive, well-documented procedures for establishing and managing BPAs under Federal Supply Schedules, prioritizing best value and fair opportunity for contractors.
Overview
FAR 8.405-3 provides detailed procedures for establishing and managing Blanket Purchase Agreements (BPAs) under Federal Supply Schedules (FSS), also known as GSA Schedules. BPAs are used to fill recurring needs for supplies or services, streamlining the ordering process and leveraging best value for the government. The regulation covers the establishment of single- and multiple-award BPAs, competitive procedures, documentation requirements, ordering processes, duration, and annual review obligations.
Key Rules
- Establishment of BPAs
- BPAs may be set up with schedule contractors that offer the best value, considering factors like price, past performance, warranty, and delivery terms. Multiple-award BPAs are preferred over single-award BPAs, especially for values over $150 million, unless specific conditions are met and documented.
- Competitive Procedures
- BPAs must be established using competitive procedures, with requirements for market research, RFQs, and fair consideration of quotes. The process varies based on whether the BPA is for supplies, services without a statement of work, or services requiring a statement of work, and whether the value is above or below the simplified acquisition threshold.
- Ordering from BPAs
- Orders must be placed in accordance with fair opportunity requirements, especially for multiple-award BPAs, and documentation of the selection process is required.
- Duration and Review
- Multiple-award BPAs generally should not exceed five years; single-award BPAs are limited to one year with up to four one-year options. Annual reviews are required to ensure continued best value and compliance.
Responsibilities
- Contracting Officers: Must ensure competitive procedures, proper documentation, annual reviews, and compliance with thresholds and justification requirements.
- Contractors: Must respond to RFQs, provide required documentation, and comply with BPA terms.
- Agencies: Oversee BPA establishment, ensure fair opportunity, and maintain documentation for audits and reviews.
Practical Implications
This section ensures BPAs are used effectively to streamline repetitive purchases while maintaining competition and best value. It imposes significant documentation and justification requirements, especially for high-value or single-award BPAs. Common pitfalls include inadequate market research, insufficient documentation, and failure to provide fair opportunity to all eligible contractors.