Can you issue a pre priced Blanket Purchase Agreement with an Economic Price Adjustment?
First, neither the FAR or DFARS prohibits the use of Fix-Price with Economic Price Adjustment on a BPA. And we know of no other established DoD Directive, Instruction, Regulation or Policy letter which prohibits the use of a fixed-price with economic price adjustment pricing arrangement on a BPA. Therefore, FAR 1.102-4(e) may apply “…If a policy or procedure… is not specifically addressed… nor prohibited… the Team should not assume it is prohibited.” We do encourage you to check CENTCOM policy memorandums and acquisition instructions to determine if there are any restrictions applicable to your AOR.
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That said; we have to point out that the use of FP-EPA brings with it some fairly stringent oversight and administration requirements, see FAR 16.203 and DFARS 216.203 (in their entirety), which eliminates the benefits of using simplified acquisition procedures. Another risk is the vendor community is typically quite vocal and forthcoming when prevailing prices rise… but not so vocal when prevailing prices fall.
The good news; in reviewing your question background, it appears using simplified acquisition procedures should give you all the flexibility you need without having to resort to the “economic price adjustment” requirements. As an example, unpriced purchase orders (see FAR 13.302-2) may be an option. If a BPA is still the best acquisition method/strategy; contractors or vendors are always free to update their price lists, at which time the contracting officer must determine the new price is fair and reasonable. This would take the same, if not less, time and effort that it would when following the administration requirements involved in doing the analysis and documentation of an economic price adjustment scenario.