There appears to be confusion and misinformation regarding this applicability. The following link states that - Individual purchases off of BPAs cannot exceed the SAT, except for commercial items under the test program or for subsistence (e.g., food) items at any value. https://dap.dau.mil/acquipedia/Pages/ArticleDetails.aspx?aid=cf6ddfbd-093d-48b2-a19a-423da202c4f4. If this is correct and the test program is permanent, than can we issue calls over SAT; or is this only applicable if agency regulations have stated we could?
However, there is a Q&A (BPA Call Order Threshold) posted to this site on 19 March 2014 that would confirm the information stated in my backgaround statement. There is also a Q&A (When establising a BPA, is an overall dollar limitation required?) on this site posted 22 June 2011 states - While there is no overall BPA dollar limitation required, please note that FAR 13.303-3(a)(3) requires that the BPA must specify a dollar limitation for each individual purchase under the BPA. Because the item in question (i.e., bulk concrete products) appears to be a commercial item, the individual purchase limitation in this case would be $6.5 million pursuant to FAR 13.303-5(b)(2).
I understand that FAR 13.500 states that - Under this test program, contracting officers may use any simplified acquisition procedure in this part, subject to any specific dollar limitation applicable to the particular procedure. Is the applicability of 13.5 as simple as understanding that 13.303-5(b) limits calls to SAT, but 13.500 states this part is subject to any dollar limitation to that procedure, - and in this case would be SAT? I came come to terms with this applicability, but it doesn't seem to make sense, unless there was a specific reason that call orders are limited to SAT. A search on FBO, shows numerous BPA's with call order limitations over SAT...granted this does not If the Test Program is now permanent. Also, is there any guidance or documentation that is clear regarding this applicability, as it doesn't seem everyone is interpreting this guidance the same way? Many contingency operations utilize 13.5 for BPA calls up to $6.5 million and I've reviewed procedural guidance that states this...again this doesn't make it correct. I would like to try and give a firm grasp on the intent of 13.5 in regards to call orders and see I can get this cleared up.
The authority you are looking for is set out in Class Deviation 2015-O0004.
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