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Question: If I award an open market commercial BPA (between $150K - $4M) under FAR Part 12 and 13, NOT FAR 15, that was advertised on FBO.gov for fair opportunity public response, am I required to post an award synopsis/announcement for my BPA award? Thoughts: FAR Part 13.303 BPAs and FAR 12.6 do not state that a post award synopsis are required, and FAR 13.106-3© states that contract awards under SAT need only to provide results when requested or as FAR 5.301 is applicable. According to FAR 5.301, the contract award needs to be announced on GFE when the 1) contract award is over $25K and i) covered under WTO/FTA OR ii) likely to results in subcontracts, 2) the contract award is over SAT and i) FSS orders of BPAs supported by limited source justifications IAW FAR 8.405-6 OR ii) TO/DOs awarded w/o fair opportunity. Then FAR 5.301(a)(3) provides exceptions to posting an award synopsis/announcement. Based on the above, my BPA award does not fit anywhere because of the following: 1) manufactured or services to be provided in the US - WTO/FTA does not apply 2) it is a BPA NOT a contract being awarded 3) the solicitation was publicized unrestricted on FBO.gov, so the public had a fair opportunity to bid What am I missing or do I have it right? I have no problem sending unsuccessful letters, but I want to make sure that I am following FAR Part 5 publications. Please provide the authority with your feedback. Thank you.
