Order Documentation Requirements without an SOW
The ordering activity shall document:
• The Schedule contracts considered, noting the contractor from which the supply or service was purchased
• A description of the supply or service purchased
• The amount paid
• When an order exceeds the simplified acquisition threshold, evidence of compliance with the ordering procedures at 8.405-1(d)
• The basis for the award decision
For all orders of any value for supplies or services not requiring an SOW, the Schedule user must document:
v The Schedule contracts considered
v The Schedule contractor selected to receive the Schedule order or BPA v A description of the supply or service acquired
v The Firm Fixed Price (FFP) amount paid
For limited source orders exceeding the micro-purchase threshold, the Schedule user must document the brand name or limited sources justification and approval.
Justifications must be prepared and approved as required by FAR 8.405-6.
Justifications for limited source restrictions may include the following:
v Only one source is capable of responding due to the unique or specialized nature of the work.
v The new work is a logical follow-on to an original Schedule order provided that the original order:
v Was placed IAW the applicable Schedules program ordering procedures v Was not previously issued under sole source or limited source procedures v Is particular to one manufacturer (a brand name item, whether available on
one or more Schedule contracts, is an item particular to one manufacturer) v An urgent and compelling need exists, and following the prescribed Schedule
ordering procedures would result in unacceptable delays.
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Notes For orders exceeding the micro-purchase threshold, FAR 8.405-1 permits a Schedule
user to consider price and other best value factors in evaluating Schedule solutions to determine the best value. Since the Schedule user is permitted to consider price and other best value factors, best practice requires the Schedule user to document both of the following:
v The evaluation methodology used in selecting the Schedule contractor to receive the order or BPA
v The rationale for any trade-offs in making the selection
Order Documentation Requirements with an SOW
The ordering activity shall document:
• The Schedule contracts considered, noting the contractor from which the service was purchased
• A description of the service purchased
• The amount paid
• The evaluation methodology used in selecting the contractor to receive the order
• The rationale for any trade-offs in making the selection
• The price reasonableness determination required by paragraph (d) of this subsection
• The rationale for using other than–
- (i) A firm, fixed-price order; or - (ii) A performance-based order
• When an order exceeds the simplified acquisition threshold, evidence of compliance with the ordering procedures at 8.405-2(c)
140 | Lesson 4: Acquisition Strategy, Competition, and Order Placement
Notes
Options
• Options may be included on Schedule orders, provided that the options:
- Are clearly stated in the requirement
- Are evaluated as part of the ordering activity’s best value determination
• Such options may be exercised on GSA Schedule contract orders, provided that:
- Funds are available
- The requirement covered by the option fulfills an existing government need - Prior to exercising an option, the ordering activity ensures that it is still in the
government’s best interest
- The options do not extend beyond the period of the Schedule contract, including option year periods
• The length of the order and the risk to the ordering activity could be considered as part of the overall evaluation of best value
Options may be included on orders placed against Schedule contracts and BPAs, if the options are clearly stated in the requirement and are evaluated as part of the ordering activity’s “best value” determination. Options may be exercised on Schedule contract orders, provided that funds are available and the requirement covered by the option fulfills an existing government need. Note that single-award BPAs cannot exceed a total of five years, i.e., one year with four, one-year options. Prior to exercising an option on a BPA, the Contracting Officer must conduct an annual review. If the BPA is a single-award BPA, then prior to option exercise, the annual review results (supporting exercise of the option) must be approved by the agency competition advocate.
Prior to exercising any option, under an order or a BPA, the ordering activity must ensure that it is still in the government’s best interest, with price and other factors considered.
Schedule task orders may be established under the preceding conditions with options that extend beyond the end of the Schedule contract period. The order option must be exercised prior to the expiration of the Schedule contract, including its option periods.
The length of the order and the risk to the ordering activity could be considered as part of the overall evaluation of best value.
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Notes
Knowledge Check 1
An ordering activity has decided to make a purchase from a multiple-award BPA for
$100,000. What are the ordering procedures to be completed?
Answer:
Knowledge Check 2
When is an ordering activity required to request a price reduction?
Answer:
Knowledge Check 3
You are part of a selection board that is seeking to implement a new payment processing software. The board has narrowed the selection down to two solutions:
(1) a system that uses new technology, and (2) one that has a longer track record of success but is $10,000 more expensive. What factors would you consider when making the best value decision?
Answer:
142 | Lesson 4: Acquisition Strategy, Competition, and Order Placement
Notes
Knowledge Check 4
You are a Contracting Officer. One of your organizations has told you they want to acquire technical support services using a GSA Schedule. What questions would you ask to determine if a GSA Schedule contract is the best solution?
Answer:
Knowledge Check 5
You are a Contracting Officer. An acquisition team wants to use a Schedule contractor for the ongoing purchase of IT equipment. You suggest the organization consider a Schedule BPA. List the benefits of using a Schedule BPA.
Answer:
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