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  • Question

    Is a Small Business Coordination (DD2579) required to establish a Blanket Purchase Agreement? If so please provide the FAR reference.


    Answer

    I believe it comes down to your agency procedures and how they define "acquisition" in the DFARS.  If they require the DD Form 2579, then it is required.  One could argue that if there is a DD 2579 submitted for the inititial BPA, you won't need it for the BPA calls.  Another can argue, if you don't have the 2579 for the initial BPA, then it would be required for each BPA call.  Or you would need a 2579 for the BPA set up and all calls.  It comes down to your agency procedures. 

    The FAR does not provide the reference to the DD 2579.  It is the DFARS that requires use of the DD 2579.  In FAR 19.201(d)(10), it basically states that the small business specialist (OSBP office representative), "Make recommendations in accordance with agency procedures as to whether a particular acquisition should be awarded under subpart 19.5..."

    FAR 19.202, basically refers to agencies shall establish procedures as to how the small business specialist reviews acquisitions and provides recommendations on set-asides.  So this leads us to the DFARS, which is DoD's procedures to comply with this requirement.

    DFARS 219.201(d)(10)(A)and(B), states  "small business specialists perform this function by—

     (A) Reviewing and making recommendations for all acquisitions (including orders placed against Federal Supply Schedule contracts) over $10,000, except those under the simplified acquisition threshold that are totally set aside for small business concerns in accordance with FAR 19.502-2. Follow the procedures at PGI 219.201(d)(10) regarding such reviews.
     (B) Making the review before issuance of the solicitation or contract modification and documenting it on DD Form 2579, Small Business Coordination Record; and..."

    DFARS PGI 219 (d)(10) states"(d)(10)(1) Agencies are not precluded from requiring that actions over $10,000, but under $150,000, that are totally set aside for small business be reviewed by the small business specialist. One example of when an agency may choose to require this review is when the agency determines that such a review is necessary to assist contracting officers in identifying opportunities for other small business set-aside programs (e.g., HUBZone, service-disabled veteran-owned) in order to meet small business goals."

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