I've looked on SAM.gov and haven't been to find any actions where someone has actually used the new RFO procedures to award a BPA under a non-FSS IDIQ. Has anyone else seen this executed yet? Just a curiosity of mine.

What reasons exist for reporting or posting that type of BPA in SAM.gov?

I haven't seen an awarded BPA of that type show up in the data, yet. However, at this point, the BPA type selections are still limited to 1) Part 8 or 2) Part 13, so not even sure how someone would accurately characterize such an award in the short term.

My agency is working on one, it looks cool and will be useful, but still in planning phase. The IDIQ needs to be updated first. The CO doesn't know of any that are active yet, and she's looked. If someone here knows of one here, I'll tell her.

2 hours ago, awhinton said:

how someone would accurately characterize such an award in the short term.

They can't, at least not in current version of FPDS, nor most (or all?) contract writing systems. FPDS is bad at multiple-award 8.4 BPAs as it is, so hopefully the update fixes these underlying issues.

On 7/9/2026 at 2:21 PM, General.Zhukov said:

My agency is working on one, it looks cool and will be useful, but still in planning phase. The IDIQ needs to be updated first. The CO doesn't know of any that are active yet, and she's looked. If someone here knows of one here, I'll tell her.

They can't, at least not in current version of FPDS, nor most (or all?) contract writing systems. FPDS is bad at multiple-award 8.4 BPAs as it is, so hopefully the update fixes these underlying issues.

I know OASIS+ has been updated to allow IDIQs and I think many of the other GSA GWACs have.

On 7/9/2026 at 10:41 AM, formerfed said:

What reasons exist for reporting or posting that type of BPA in SAM.gov?

I meant CARs since FPDS has moved over to SAM, although it's not even clear to me if FPDS has been updated to allow someone to do a BPA off a non-FSS IDIQ.

1 hour ago, Freyr said:

not even clear to me if FPDS has been updated to allow someone to do a BPA off a non-FSS IDIQ

Definitely not. sam/fpds data in production as of today uses data dictionary version 1.5, which has Part 8 and 13 BPA Calls, but nothing for a non FSS IDIQ 2nd iter BPA or that BPA's calls. See screenshot below.

When will it happen?

Short version: It'll be a while.

Long version. Adding Part 16.5 BPAs and Calls is much more work than you'd think, because of FPDS's data architecture. It's way more than just adding a value to a field. 1) Adding these new BPAs/Calls would set off a cascade of downstream changes throughout FPDS, as the' requirement state' is very important (all the validations use requirement state, so each and every validation will need to be updated). Upstream, all the feeder systems/reports (like CARs) also will need to be updated to provide this new data. That's a whole lot of coordination, waiting for feeder systems to update, then integration testing, etc. etc., etc. 3) If FPDS goes with this approach, it'll have three slightly different BPA Calls, which isn't wrong, but is clumsy. The alternative more elegant and efficient implementations of Part 16.5 BPAs are all equally (or more) involved. An incremental roll-out could be faster but has a big downside - ultimately it will have to depend on user-input and users make lots of errors, and necessarily means a retroactive data fix that, itself, is very high effort.

Always following. A couple of thoughts -

I think the reporting via electronic systems will stymie trying to find an example. Too bad as it would be helpful as the authority to do so gets legs....

Oh but wait is there really regulatory authority to do so (tongue in cheek), afterall the RFO says...

16.507-2(3) "Blanket purchase agreements. If authorized in the multiple-award contract according to 16.504(f)(8)..." but if there is not 16.504(f)(8) how can a BPA in a multiple award IDIQ be authorized? Or in other words seems like one more correction coming to the RFO!

On 7/9/2026 at 9:37 AM, Freyr said:

I've looked on SAM.gov and haven't been to find any actions where someone has actually used the new RFO procedures to award a BPA under a non-FSS IDIQ. Has anyone else seen this executed yet? Just a curiosity of mine.

Assuming this ends up as a valid technique, I think a big question will be "why use it at all"? I can see it making sense for multiple-agency contracts, similar to how the GSA Multiple Award Schedule works. But for single-agency IDIQs? It's hard to see it. Maybe some practitioner will uncover a really innovative use case someday....

20 hours ago, FrankJon said:

"why use it at all"

I think of FAR 16.5 BPAs as correcting an indefensible inconsistency in the FAR, rather than a new solution being created to address an existing problem.

That said, the timing is convenient. The current policy environment disincentivizes — and in some cases prohibits — the creation of new IDIQs. As a result, COs are expected to satisfy requirements through existing contract vehicles. Where those vehicles are IDIQs (like GWACs), COs can now establish BPAs directly against them under FAR 16.5. This gives COs a mechanism to achieve the same contracting objectives that were previously met by standalone IDIQs, while remaining compliant with policies that favor the use of existing sources.

This is a fairly niche application. I wouldn't expect to find many instances of a requirement that is 1) indefinite enough that is should be an IDIQ/BPA, and 2) there is no suitable MAS, and 3) there is a suitable IDIQ. Non-DoD use cases could be medical research or construction/A&E.

2 hours ago, General.Zhukov said:

I think of FAR 16.5 BPAs as correcting an indefensible inconsistency in the FAR

Which inconsistency is that?

Inconsistency: The tool (BPA) existed, the need (streamlined repetitive ordering against an existing vehicle) existed across all IDIQ types, but the authority was only codified for a subset of IDIQs - MAS.

Indefensible: There is no longer any policy rationale (that I know of) for treating a subset of IDIQs differently.

Agree with your inconsistency point. I’ve always believed the BPA concept was available under IDIQ contracts and proper but not necessarily labeling it as a BPA.

On 7/15/2026 at 2:01 PM, General.Zhukov said:

Inconsistency: The tool (BPA) existed, the need (streamlined repetitive ordering against an existing vehicle) existed across all IDIQ types, but the authority was only codified for a subset of IDIQs - MAS.

Indefensible: There is no longer any policy rationale (that I know of) for treating a subset of IDIQs differently.

I think it’s defensible because because fair opportunity is not the competitive standard for orders placed against GSA schedules but it is the standard for orders placed against multiple award IDIQs. It’s not a “policy rationale” but a statutory rationale. The RFO didn’t change the statute. The RFO drafters are just hoping this sticks.

19 hours ago, FrankJon said:

It’s not a “policy rationale” but a statutory rationale.

Agree. That is why I put the 'policy' qualifier in my reply. There is no good policy or functional rationale, but there definitely is a good statutory rationale. I look forward to the creative counterarguments about why it isn't ultra vires because the IDIQ awardees agreed, or BPA Calls are legally distinct from "task or delivery orders" and so exempt from 4106, or whatever.

38 minutes ago, General.Zhukov said:

Agree. That is why I put the 'policy' qualifier in my reply. There is no good policy or functional rationale, but there definitely is a good statutory rationale. I look forward to the creative counterarguments about why it isn't ultra vires because the IDIQ awardees agreed, or BPA Calls are legally distinct from "task or delivery orders" and so exempt from 4106, or whatever.

Will certainly be interesting if it sticks around long enough to be litigated!