Sign In
  • Question

    Does this limitation have to match the IGCE?


    Answer

    This appears to be a local interpretation by your Procurement Analyst. The contracting officer is called upon by the Federal Acquisition Regulation (FAR) reference you cited in the background to establish “…a reasonable maximum quantity based on market research, trends on recent contracts for similar supplies or services, survey of potential users, or any other rational basis.”  However, this refers to Indefinite-quantity Contracts not Blanket Purchase Agreements (BPAs).  The correct cite for BPAs is FAR 16.701 which will then refer you to FAR 13.303.  Once there you will see at FAR 13.303-7 a reference to “…its total dollar limitation, if any…” which I assume is akin to your BPA Maximum Dollar Limitation per fiscal year.  When I performed a simple Goggle search using blanket purchase agreement master dollar limitation (without quotes), I found that two hits (#1 and #3) presented BPA documents (both were Army documents) that used the term Master Dollar Limit.
     
    You indicate that you have adjusted the BPA Master Dollar Limitation based on a discussion with your customer in the light of new information concerning a BRAC consolidation.  This is new data that was discovered after the Independent Government Cost Estimate (IGCE) was prepared.  In my view that would be cause to adjust the IGEC based on this new information.  Remember that the IGCE is an estimate and, as such, is dependent on the input data that was used to prepare it.  If the input data changes the IGCE should be adjusted accordingly. 
     
    I do not find any requirement within the FAR, the Department of Defense FAR Supplement or the Army FAR Supplement that requires the two figures to match. 
     
    Lastly, I could not find any definition of the term Master Dollar Limitation in the FAR or the Financial Management Regulation (FMR).
     
    As with most decisions required by the FAR, the establishment of a maximum dollar limit on a BPA is a decision of the Contracting Officer.  Since, there is no specific list in FAR 13.303 for the Contracting Officer to consider in establishing the BPA limit along the lines of FAR 16.504(a)(1), it would be open to the Contracting Officer’s best judgment which would certainly include the IGCE but would not be limited to it. 

    Open full Question Details