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    Is a Determination of Best Procurement Approach Direct Acquisition D&F required for FSS orders less than $500K.


    You can solicit a $350K requirement through GSA without doing the Determination of Best Procurement Approach.  This determination is not required for orders under $500K.  You can find this answer at 8.404 (b) (2) and 17.502-1, both attached below.  There are no supplements to this wording at the DFARS /PGI or the Army Supplement.  
    8.404 – Use of Federal Supply Schedules.
    (1) The contracting officer, when placing an order or establishing a BPA, is responsible for applying the regulatory and statutory requirements applicable to the agency for which the order is placed or the BPA is established. The requiring agency shall provide the information on the applicable regulatory and statutory requirements to the contracting officer responsible for placing the order.
    (2) For orders over $500,000, see subpart 17.5 for additional requirements for interagency acquisitions. For example, the requiring agency shall make a determination that use of the Federal Supply Schedule is the best procurement approach, in accordance with 17.502-1(a).
    17.502-1 – General.
    (a) Determination of best procurement approach—
    (1) Assisted acquisitions. Prior to requesting that another agency conduct an acquisition on its behalf, the requesting agency shall make a determination that the use of an interagency acquisition represents the best procurement approach. As part of the best procurement approach determination, the requesting agency shall obtain the concurrence of the requesting agency's responsible contracting office in accordance with internal agency procedures. At a minimum, the determination shall include an analysis of procurement approaches, including an evaluation by the requesting agency that using the acquisition services of another agency—
    (i) Satisfies the requesting agency's schedule, performance, and delivery requirements (taking into account factors such as the servicing agency's authority, experience, and expertise as well as customer satisfaction with the servicing agency's past performance);
    (ii) Is cost effective (taking into account the reasonableness of the servicing agency's fees); and
    (iii) Will result in the use of funds in accordance with appropriation limitations and compliance with the requesting agency's laws and policies.

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