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Is contract bundling an issue under Schedules?

 

The short answer is YES!  While there are no special considerations for Schedules compared to other contracting techniques, there is a pervasive misconception among some contracting professionals that the Multiple Award Schedules are not covered by the bundling regulations described in FAR 19.202-1 and 7.107.  This is understandable since nothing else in Part 19 applies unless the contracting officer chooses, at his or her discretion, to invoke Part 19 (see this post for more information on set asides using Schedules). 

In terms of bundling, FAR 8.404(a) clearly states that FAR subpart 19 does not apply to task orders or BPAs placed against Federal Supply Schedule contracts “except for the requirement at 19.202-1(e)(1)(iii))” which loops us back to the bundling issue.  Is your procurement potentially a “bundled requirement” within the meaning of the regulations?  If so, you are NOT exempt from these requirements just because you are using FAR 8.4 procedures.

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