Morning All!

Had a question around use of labor categories in a BPA won as a GSA CTA.  Let's say the CTA has 2 members, each with their own GSA schedule (same schedule for both).  One firm has labor categories on it's schedule that the othe does not.  During the bid process, BPA labor categories were created and mapped from each member's schedules.  Ultimately then, the BPA includes labor categories that are not on one CTA member's schedule.

If a task order released under the BPA dictates labor categories, and only one CTA member has those labor categories on their GSA schedule, could the other CTA member also use that labor category?  If yes, how would that be reported to GSA (since it's not on their schedule)?  If no, could one CTA member sub to another to use the labor category?

Hope that was clear to follow, thanks in advance for any help!

I no of no regulation that addresses that issue. I presume it is a matter of BPA interpretation. Develop your own interpretation and then discuss the matter with the CO who awarded the BPA.

This problem is usually avoided by the CTA BPA team not making a task order proposal for a particular effort to the customer that combines multiple holder labor categories. And if there is the need for multiple holder labor categories, have the customer split the order so that individual schedule holders can perform and report their individual efforts. I would not recommend that one holder use another’s labor category as their own. Look to the IFF instructions for clarification. See question 22 on the GSA site. https://www.google.com/ One holder can indeed subcontract to another holder, but then the prime holder reports the entire effort as their own. Sometimes in the CTA agreement between holders (which frequently has to be provided to the GSA) there are terms to handle these situation

Correct URL

https://72a.gsa.gov/ifffaq.cfm