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GSA Schedules and IDIQ Orders

Can you place Indefinite Delivery Indefinite Quantity (IDIQ) orders against Federal Supply Schedules (FSS)?
Currently, there is no policy in FAR Subpart 8.4 that strictly prohibits the placement of an IDIQ order against a FSS; however, it is not an appropriate order type for the following reasons:

An IDIQ is a contract type and not an order type. There are only two types of orders that may be placed off IDIQ contracts: delivery orders and task orders. Ordering procedures for IDIQ contracts are governed by FAR 16.505, whereas the ordering procedures for FSS are governed by FAR 8.405. The procedures in FAR 16.505 are not equivalent to FAR 8.405, and are not appropriate when ordering commercial products and services through FSS vehicles. Selecting a contractor to provide goods and services under their FSS contract using any other procedure than FAR 8.405 would violate the Competition in Contracting Act of 1984 (CICA). In other words, the procedures in FAR Subpart 8.4 apply to individual orders under FSS contracts (see FAR 8.403), which would not cover setting up IDIQs for subsequent orders.

By placing an IDIQ order against a Federal Supply Schedule, you are limiting the pool of vendors being considered when setting up the IDIQ to FSS contract holders. This is not done under the authority of FAR Subpart 8.4, thus not satisfying competition requirements.

Business Judgment
Placing IDIQ orders against Federal Supply Schedules is not a sound business decision. A better solution would be to set up a Blanket Purchase Agreement (BPA) in accordance with FAR 8.405-3.

There is a perception that BPAs do not provide a firm enough commitment by the contractor to provide the goods and services. Ordering activity would rather set up an "IDIQ order" to ensure the contractor is held to the agreement. However, the FSS contract already requires the contractor to accept all orders within the ordering limitations (see clause 52.216-19 Order Limitations). Remember, you can’t have additional terms and conditions in the BPA that conflict with the underlying Schedule’s terms and conditions.

 

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