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    Are we allowed to issue a contract with a current date but having coverage time backdated for one month? I did not think this was allowed.


    Answer

    The following response is based solely on the question and background information provided.  As we do not have all the facts particular to your situation, we highly recommend you consult, as applicable, your contracting officer and/or Legal Office for further guidance. Here are the FAR, DFAR, and AFAR references for BPAs.  I would recommend checking with your specific agency policy section for additional guidance on your situation..
     
    Any contract must be within the terms of the BPA.  With multiple vendors to choose from (and assuming no other restricting terms and conditions set in the BPA itself), you are able to award, but need to submit a synopsis.  
     
    FAR 5.101 -- Methods of Disseminating Information.
      (a) As required by the Small Business Act (15 U.S.C. 637(e)) and 41 U.S.C. 1708, contracting officers must disseminate information on proposed contract actions as follows:
      (1) For proposed contract actions expected to exceed $25,000, by synopsizing in the GPE. 
     
    FAR 5.202 -- Exceptions.
    The contracting officer need not submit the notice required by 5.201 when --
      (a) The contracting officer determines that --
      ....    (13) The proposed contract action--
      (i) Is for an amount not expected to exceed the simplified acquisition threshold;
      (ii) Will be made through a means that provides access to the notice of proposed contract action through the GPE; and
      (iii) Permits the public to respond to the solicitation electronically... 
     
    FAR 13.303-5 -- Purchases Under BPAs.
      (a) Use a BPA only for purchases that are otherwise authorized by law or regulation.
      (b) Individual purchases shall not exceed the simplified acquisition threshold. However, agency regulations may establish a higher threshold consistent with the following:
      (1) The simplified acquisition threshold and the $7 million limitation for individual purchases ($13 million for purchases entered into under the authority of 12.102(f)(1)) do not apply to BPAs established in accordance with 13.303-2(c)(3).
      (2) The limitation for individual purchases for commercial item acquisitions conducted under Subpart 13.5 is $7 million ($13 million for acquisitions as described in 13.500(c)). 
      (c) The existence of a BPA does not justify purchasing from only one source or avoiding small business set-asides. The requirements of 13.003(b) and Subpart 19.5 also apply to each order.
      (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 (see 13.105) and make the purchase as appropriate; and
      (2) Establish additional BPAs to facilitate future purchases if --
      (i) Recurring requirements for the same or similar supplies or services seem likely; 
     
    DFARS 213.303-5 Purchases under BPAs.
      (b) Individual purchases for subsistence may be made at any dollar value; however, the contracting officer must satisfy the competition requirements of FAR Part 6 for any action not using simplified acquisition procedures.
      (ii) Qualified sources are willing to accept BPAs; and
      (iii) It is otherwise practical to do so.
     
    AFARS 5113.303 Blanket purchase agreements (BPAs).
    5113.303-1-90 General.
      (a) It is preferable to have multiple BPAs for similar items and to establish prices using reverse auctions among BPA holders. If quantities are too small and not conducive to using a reverse auction, then when practicable, contracting officers should establish pre-priced BPAs by negotiating firm unit prices for specific periods of time or by incorporating suppliers’ price lists or catalogs in BPAs.
      (b) Contracting officers should not establish blanket purchase agreements for supplies or services when the use of unpriced purchase orders is appropriate (see FAR 13.302-2). 
     
    5113.303-5 Purchases Under BPAs.
      (b)(1) Individual purchases under BPAs established in accordance with FAR 13.303-2(c)(3) may exceed the simplified acquisition threshold.
        (2) Individual purchases of commercial items under BPAs, other than BPAs established in accordance with FAR 13.303-2(c)(3), may exceed the simplified acquisition threshold up to the dollar limitation specified in FAR 13.500.
      (c) Sole source individual commercial item purchases exceeding the simplified acquisition threshold shall comply with the documentation requirements of FAR 13.501(a). 
     
    Based on the above, the one exception (#13) that might apply stills requires the award "will be made through a means that provides access to the notice of proposed contract action through the GPE".  You may solicit from the vendors, but will need to let industry be aware, primarily to let others know of potential subcontract opportunities. 
     

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