FAR 13.303-6, Annual BPA Review procedures.

[1102ForLife]

My organization is trying to comply with FAR 13.303-6, the requirement to annual review BPAs, however we are a little lost on how to proceed. Has anyone ever completed an annual BPA review? If so, would you be interested in providing some details on what exactly you did?

Any info would be appreciated.

Thanks!

[1102ForLife]

I guess nobody out there has conducted an annual BPA review before?

[Cajuncharlie]

Last time I conducted an annual BPA review was under ASPR 3 Part 6, if memory serves.

If you can't find anything to go by, suggest you use FAR 13.303-6 to develop a checklist you can use for the annual review. Document your search for guidance and the negative results as the reason for developing your own checklist.

[Guest Vern Edwards]

First, BPA-holder performance should be reviewed to determine whether the BPA should be renewed.

Second, check for currency of any clauses in the BPA. BPAs should be updated with the latest clauses

Third, if the BPA is priced, market research should be conducted to determine if they are still fair and reasonable. If not, negotiate new prices.

Fourth, if there is a list of items or services in the BPA, it should be checked for currency.

Fifth, if there is a list of items and specifications have been incorporated into the BPA, they should be updated as necessary.

Sixth, call placement authorizations, limitations, and procedures should be reviewed and updated as necessary.

Seventh, addresses, points of contact, phone numbers, and invoicing terms and instructions should be updated, if necessary.

Got the idea now? This shouldn't have required a lot of thought. If your office cannot figure this kind of thing out for itself, and if it didn't plan ahead when it issued BPAs, maybe it shouldn't be permitted to have BPAs.

[1102ForLife]

Vern,

That does give me a better idea yes. I realize that we can use our own discretion to develop our internal procedures. With regards to your comments about being "permitted to have BPAs." .... well I agree!. I don't think our office fully understands how to properly use them. Here are some examples:

1. The frequency of our requirements don't justify having BPAs set up. We have about 65 BPAs in place. In the past FY, we issued only 23 calls...some BPA holders obviously didn't get any calls. To top it off, most of the calls were under the micro-purchase threshold, so it probably would have been just as easy to issue multiple purchase orders throughout the year.

2. We treat each BPA requirement like its a contract, thus we gain no benefit from using BPAs. Each requiremnent (even those under the micro-purchase threshold) is competed via an RFQ. A Source Source Selection Decision and Price Reasonableness Memorandum, is drafted up, and everything is then reviewed by another KO who wordsmiths the documents...In my mind, BPAs should be used for "simple" services and supplies..like gravel or office supplies...where the KO/Ordering Officer can issue calls immeadiately (as long as calls are evenly rotated amongst BPA holders ) , or using Fair Opportunity procedures..

3. Our contract writing system, PD2, is not a good system for handling Call Orders for services that are more complex.. Doing a modification to a call order is cumbersome and confusing. There is no "Summary of Changes" nor any Narrative field to describe what the modification is doing. Instead you have to write it into the CLIN narratives

So with that said, why are we using BPA's? Well one problem is that our parent agency shoved them down our throats a few years back. Apparently they had some initiative where they wanted to see their contracting organizations using more BPA's...so thats what we did...and as happens all too often in the government, bad ways of doing things get carried forward for many years onward..

So Vern, you are probably correct. We probably should not be permitted to use BPAs for these requirements. However since I have been tasked with developing the annual review procedures, I am hoping to use this opportunity to raise awareness of the above issues.

[Guest Vern Edwards]

We treat each BPA requirement like its a contract, thus we gain no benefit from using BPAs. Each requiremnent (even those under the micro-purchase threshold) is competed via an RFQ. A Source Source Selection Decision and Price Reasonableness Memorandum, is drafted up, and everything is then reviewed by another KO who wordsmiths the documents...In my mind, BPAs should be used for "simple" services and supplies..like gravel or office supplies...where the KO/Ordering Officer can issue calls immeadiately (as long as calls are evenly rotated amongst BPA holders ) , or using Fair Opportunity procedures.

Each call against a BPA is a separate contract once the BPA holder accepts it. A BPA is not a contractual agreement. It is a charge account. The labor savings come from not having to prepare a new purchase order each time you place a call, since the call incorporates the terms of the BPA. That's why you have to review the BPA at least annually. Labor savings also come from the contractor's agreement to bill the government once each month instead of separately for each call.

[dcarver]

3. Our contract writing system, PD2, is not a good system for handling Call Orders for services that are more complex.. Doing a modification to a call order is cumbersome and confusing. There is no "Summary of Changes" nor any Narrative field to describe what the modification is doing. Instead you have to write it into the CLIN narratives

You establish a new contract off of the parent BPA for every call. Using the 1449 should solve your issue (used PD2 and made calls off of BPAs, allbeit much larger than the micro purchase threshold). You then modify the contract established from the call, rather than the BPA.