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Can An Ordering Agency Award An IDIQ Task Order Using The GSAs Multiple Award Schedule Program?

 

One of those questions we are asked on a consistent basis is, “can I award an Indefinite Delivery Indefinite Quantity (IDIQ) task order off of a GSA Federal Supply Schedule?” Some may not like my answer, but “It depends”. But what does it depend upon? Well, it depends on how far a CS/CO wants to stretch the limitations of the Federal Acquisition Regulation (FAR).  Before I go into stretching the FAR, which was the way I was taught to use the FAR by some incredible COs when I was an intern many years ago (Thank you for your patience BJ P., Pat B., and Teresa!), let’s talk about some Schedules contract basics. 

Did you know that GSA Federal Supply Schedules (the terms Federal Supply Schedules, Multiple Award Schedules (MAS), and GSA Schedules Program are interchangeable) are awarded as FAR Part 12, IDIQ variant contracts? Before I continue, this revelation may already dampen some acquisition professional’s enthusiasm for awarding an IDIQ task order. Now that you know that Schedule Contracts are IDIQs, do you believe that you can award an IDIQ off of an IDIQ? For the sake of those who insist on considering an IDIQ task order, let’s continue. As you all know (or at least I hope you do!), that ordering agencies get their ordering procedures for using the Schedules program from FAR subPart 8.4. 

By the way, in case you haven’t seen me present our “Using GSA Schedules for Professional Services” seminar, or know me personally, I have a streak of sarcasm. Okay, maybe more than a streak! We now return to our regularly scheduled program.

Specifically, FAR subPart 8.4 identifies two types of orders (task/delivery) and one contract vehicle (BPA) in the use of the Schedules program.  Is there any mention of IDIQ contracts in FAR subPart 8.4? No. While not specifically prohibited by the FAR or schedule contract terms and conditions, I don’t believe that IDIQs were envisioned (they have not been tested by protest) as an appropriate ordering mechanism for using the Schedules Program. I do know that IDIQs IAW FAR Parts 16.504(a)(4)(ii) and 16.54(a)(4)(vi), do require ordering agencies to complete the requirements cited in the FAR. Have I convinced you yet?

Oftentimes acquisition professionals revert to what we are comfortable with (I am an old school FAR Part 15 Contracting Officer, guilty as charged!), instead of using the tools that are provided by the FAR.  In the case of an agency that is acquiring supplies or services of a recurring nature, I would recommend a Blanket Purchase Agreement (BPA) using FAR subPart 8.405-3 (Click here for BPA Toolkit). This is different than a FAR Part 13 BPA.  Do not make your BPA a FAR Part 13 BPA, as FAR Part 13 is not applicable to the schedule program IAW FAR Part 8.404(a).  Neither are FAR Parts 14 or 15. See FAR Part 15 is not applicable. Oh my, this is turning Clemensian in nature (inside joke, sorry Dave!).  Wow, I think I’m getting ready to go off on another tangent! Sometimes I can’t help myself. Never mind.  Why would you want to award an IDIQ with the limitations that come with it? Would you like to read about contrasting differences/limitations between FAR 8.4 BPAs and IDIQs? Click Here.

Finally, can you award an IDIQ contract? I am unsure as the proper answer, but I wouldn’t recommend it when we already have the FAR 8.4 provided BPAs!

We welcome comments on our topics.  Let us know what you think!

For more information on BPAs: Click Here.

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