BPA Call Order Threshold and FAR 13.5

[dneal23]

Our office has been issuing BPA call orders over SAT. Recent BPA training highlighted that IAW FAR 13.303-5, calls shall not exceed SAT unless agency regulations may establish a higher threshold consistent with FAR 13.5. I had asked previously about this, but was refered to 13.5 as the authority to issue calls over the SAT. It is my understanding that there are no known agency regulations allowing calls to be issued over SAT. There are various Q&A's on DAU Ask a Professor and even guidance on the DAU site that conflicts with each other on the applicability of 13.5 when issuing BPA call orders.

I understand that FAR 13.500 states that "Under this test program, contracting officers may use any simplified acquisition procedure in this part, subject to any specific dollar limitation applicable to the particular procedure. Is the applicability of 13.5 as simple as understanding that 13.303-5 limits calls to SAT, but 13.500 states this part is subject to any dollar limitation to that procedure....and in this case the limitation would be SAT.

There is a general resistance to limiting call orders to the SAT and I'm caught in the middle of trying to interpret the guidance correctly, while ensuring everyone can understand how this alters "how things have always been done." I see how BPA's can be used and often times they aren't issued correctly, so I can understand having limitations. Part of me feels the answer I am seeking is straightfoward and simple, but with the different responses I've read and information available, I welcome any discussion or thoughts on this matter.

[Don Mansfield]

Which agency do you work for?

[dneal23]

USACE

[Don Mansfield]

dneal23,

I'm with you. FAR 13.303-5( b ) states:

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 $6.5 million limitation for individual purchases ($12 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 $6.5 million ($12 million for acquisitions as described in 13.500(e)).

The FAR sets a limit for individual purchases at the SAT. It authorizes agencies to set a higher threshold in their regulations, but neither DoD nor the Army did that.