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    Is this a CICA violation to award a mod for 1.3M against a BPA was for $489K?


    I am making the assumption the BPA was written with a stipulated aggregate amount of $498K and now the requiring activity wants the agreement to be raised to an aggregate of $1.789 M.  The additional $1.3M will be used to update the physical security master plan.

    There are a couple issues I am going to look at. 
    The first issue is whether this is commercial or non-commercial.  If this is noncommercial then each order placed against the BPA should not exceed the simplified acquisition threshold. The update to the physical security master plan would exceed the threshold so should not be done against this BPA.  If this is commercial then the limit is $6.5M

    The second issue deals with
    FAR 13.303-5(c) The existence of a BPA does not justify purchasing from only one source.  It goes on in (d) If, for a particular purchase greater than the micro-purchase threshold, there is an insufficient number of BPAs to ensure maximum practicable competition, the contracting officer shall- (1) Solicit quotations from other sources and make the purchase as appropriate.

    So based on the assumptions I made you would need to solicit quotations from other sources to update the physical security master plan.

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