5 hours ago, Neil Roberts said:

...take appropriate additional steps that may include additional clauses prescribed for the $1M level...

Neil,

Please read FAR 13.303-4(b).

A FAR 13 BPA is not an acquisition -- it is not a contract.  For clauses, reviews, small business coordinations, competition, and every other purpose, the individual purchase limit is the only dollar amount that matters -- the potential aggregate (or maximum), if one is specified, is irrelevant (and isn't even mandatory).

You are in good company -- many, many people in the federal acquisition community do not understand FAR 13 BPAs, and they make the same mistakes that you are making.  They treat a FAR 13 BPA erroneously as a procurement based on the maximum, rather than correctly as a method for repeat purchases within the individual purchase limit.  [Please note that this entire thread deals with FAR 13 BPAs for simplified acquisitions, not BPAs against schedule contracts under FAR 8.4.]

I hope this discussion helps the OP and other readers understand correct principles.

9 hours ago, Neil Roberts said:

I know of no case that stands for the proposition that any document with a header "BPA" is automatically not a contract.

Because not all documents with the header "BPA" are actually BPAs. FAR part 13 BPAs are required to contain the terms and conditions at FAR 13.303-3(a), including--

(2) Extent of obligation. A statement that the Government is obligated only to the extent of authorized purchases actually made under the BPA.

10 hours ago, ji20874 said:

you are in good company -- many, many people in the federal acquisition community do not understand FAR 13 BPAs, and they make the same mistakes that you are making.I hope this discussion helps the OP and other readers understand correct principles.

I hope readers come to their own conclusion. You and I do not agree on anything with respect to the Department of Defense DFARS (not FAR) Form that is THE subject of this posting with a background associated with FAR Part 13 and other type BPA's that result in contracts for goods or services.

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