Blanket purchase agreements (BPAs)
FAR 8.405-3 mandates competitive, well-documented, and regularly reviewed BPAs under Federal Supply Schedules to ensure best value and compliance for repetitive government needs.
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 repetitive needs for supplies or services, streamlining the ordering process and promoting best value for the government. The regulation covers the establishment of single- and multiple-award BPAs, competitive procedures, ordering processes, documentation requirements, duration, and annual review obligations. It emphasizes competition, transparency, and documentation to ensure compliance and value.
Key Rules
- Establishment of BPAs
- BPAs can be set up with schedule contractors that offer best value, considering factors like price, past performance, and delivery terms. Multiple-award BPAs are preferred over single-award BPAs, especially for values over $100 million, which require special justification.
- Competitive Procedures
- Specific procedures apply based on whether the BPA is for supplies/services without a statement of work (SOW) or for services requiring an SOW, and whether the value is above or below the simplified acquisition threshold. At least three contractors must be considered unless justified otherwise.
- Ordering from BPAs
- Orders must follow fair opportunity requirements, especially for multiple-award BPAs, with documentation of the selection process and compliance with competition rules.
- Duration and Review
- Multiple-award BPAs generally last up to 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 competition, proper documentation, annual reviews, and compliance with thresholds and justification requirements.
- Contractors: Must respond to RFQs, provide best value, and comply with BPA terms and ordering procedures.
- Agencies: Oversee BPA establishment, ensure fair opportunity, and maintain documentation for audits and reviews.
Practical Implications
- This section ensures BPAs are used efficiently, competitively, and transparently, reducing administrative burden for recurring needs. Failure to follow documentation, competition, or review requirements can result in protest, audit findings, or contract disputes.