FAR Subpart 8.4 Simplifies the Solicitation Process

FAR Subpart 8.4 provides ordering procedures for placing orders against a GSA Schedule. FAR Part 13, Simplified Acquisition Procedures, Part 15, Contracting by Negotiation, and FAR Part 19, Small Business Programs (except for 19.202-1(e)(1)(iii)), are NOT applicable to orders placed against FSS, except that FAR 13.303-2(c)(3) allows for BPAs to be established with FSS contractors, if not inconsistent with the terms of the applicable Schedule contract. Under FAR Subpart 8.4 ordering activities do NOT:

• Conduct a formal “negotiated procurement”
• Issue a solicitation for 30 days (or any other pre-determined time)
• Synopsize the requirement on FedBizOpps, unless an order or BPA is awarded under a limited sources justification for an award exceeding the SAT (See FAR 8.405-6(a)(2)); only a post-award synopsis is required
• Conduct “discussions”
• Conduct formal “debriefings”
• Use FAR Subpart 15.3 concepts and procedures