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    Can BPA Master Agreements be issued over the SAT with the rescinding of FAR 13.5?


    I'm unaware of any restriction against establishing a BPA with an estimated value greater than the simplified acquisition threshold. The GAO has asserted that agencies are not required to request proposals or to conduct a competition before establishing BPAs. However, after a BPA is established, otherwise applicable competition requirements apply to all orders under the BPA. So, the SAT restriction (currently $150,000 or less) applies to to individual orders made against the BPA, rather than the BPA Agreement itself. 

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