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    Is there a duration period for a single and multiple award IDIQ as it is with a BPA? Can IDIQ have option years as in BPA? For example: 8.405-3 Blanket Purchase Agreements (BPAs). (d) Duration of BPAs. (1) Multiple-award BPAs generally should not exceed five years in length, but may do so to meet program requirements. (2) A single-award BPA shall not exceed one year. It may have up to four one-year options.


    Answer

    The Federal Acquisition Regulation establishes very few limitations on the ordering period of Indefinite Delivery/Indefinite Quantity (IDIQ) contracts (FAR subpart 16.5).   FAR 16.505(c) limits the ordering period for task order contracts for advisory and assistance services (AAS) to not more than 5 years with the exception of requirements arising from law or AAS services incidental to supply/services. Blanket Purchase Agreements (BPA) pertain to buying on federal supply schedules (FSS) and is covered at FAR subpart 8.4.  FAR 16.500 (C) reinforces the concept that if buying from, specifically, an FSS, the rules at FAR subpart 8.4 apply.  When the Department of Defense establishes a contract vehicle which performs a lot like an FFS without actually being administered by the general services administration (GSA) or the veterans administration (VA) the rules at FAR subpart 8.4 do not apply (FAR 8.402(a). These findings naturally lead the question, "How far out are the limits?"  Can we establish a base IDIQ with a five year ordering period and include four options, each of a five year duration?

    The answer to this issue lies in two areas.  First, the intent of FAR parts 5 and 6. FAR part 5 deals with getting the word out on the street that we are buying in order to give everyone that wants to, especially small business, a chance to throw their hat in the ring. FAR part 6 gives instruction on providing for the maximum competition practicable in every acquisition situation. FAR 16.504(a)(4)(I) requires the contracting officer to establish the period of the IDIQ and FAR 16.504(a)(4)(ii) establishes the maximums and minimums of the requirement against which orders are to be placed.  These requirements must be realistic and supported by sound thinking (FAR16.503(a)(1)). There is a real and constant tension between the government's right to find efficiency and the public's right to transparency and fair opportunity at FAR 16.505(b)(1).  While contracting officers have great latitude with regards to ordering period in an IDIQ; one can quickly recognize that if pushed too far a longer ordering periods become unreasonable and indefensible.

    This discussion has been limited to the IDIQ vehicle and its ordering period as the individual orders must follow the 'purpose, time, and amount' requirements of fiscal law.

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