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Agency Business Cases Now Required by OFPP

In response to concerns about overlap and duplication of contracts for frequently purchased goods and services, the Office of Federal Procurement Policy (OFPP) has issued guidance that requires agencies to submit a business case for all governmentwide acquisition contracts (GWACs), blanket purchase agreements (BPAs), and agency-specific contracts.

This requirement applies to all GWACs released after December 31, 2011, regardless of estimated value. For BPAs and agency-specific contracts, the business case requirement must be implemented if the estimated value is greater than or equal to:

•  $250 million and the release date falls between January 1, 2012 and September 30, 2012,
•  $100 million and the release date falls in fiscal year 2013, or
•  $50 million and the release date falls in fiscal year 2014.

The required business case process includes the following four steps:

1. Preparing a preliminary business case that looks at issues of scope and duplication using the OFPP template,
2. Posting the preliminary business case on the OMB MAX website for at least 15 days,
3. Determining whether to proceed with a new procurement or cancel the BCA based on feedback, and
4. Canceling or finalizing the business case by completing the remaining sections and obtaining necessary approvals from agency official(s).

In the case of BPAs and multiagency- and agency-specific contracts, OMB may require agencies to submit approved business cases. Submission of approved business cases is required for GWACs.

To learn more about the requirement, the OFPP memo can be found here.
 

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