Ordering Procedures – FAR 8.405-1

When is an SOW not Required?

According to FAR 8.405-1, when acquiring fixed-price services or supplies through GSA Schedules, an SOW is not required when the dollar value of the order or BPA:

• Is at or below the micro-purchase threshold. You may place the order directly with the selected vendor. FAR procedures for acquisitions at or below the micro-purchase threshold emphasize simplicity and fair treatment. Supporting documentation, including extensive information, collection, and evaluation, is not required. However, the Schedule user should attempt to distribute orders among Schedule contractors.
• Exceeds the micro-purchase threshold, but not the simplified acquisition threshold. You should obtain at least three (3) quotes (always documenting your contract file and select the best value quote).
  • Survey at least three Schedule contractors, considering price and other identified best value factors.
  • Consider ordering from contractors that help you meet your agency’s socioeconomic goals.
  • Use an RFQ only if it is the most efficient method for gathering the information needed to evaluate solutions available under GSA Schedules. When using an RFQ, the Schedule user must provide the RFQ, including the evaluation criteria, to any contractor under the appropriate Schedule that requests a copy.
  • The Schedule user should seek a price reduction when:
    • Market research reveals that the supply or service is available elsewhere at prices lower than those available from Schedule contractors.
    • The Schedule contractor has been or will be selected to provide recurring requirements and the size of the recurring orders appears to merit a price reduction.
    • Market research identifies other information indicating that a price reduction is appropriate.
• Exceeds the SAT, or when establishing a BPA. The ordering activity shall seek a price reduction, survey more than three contractors, and select the best value quote. If further price reductions are not offered, an order may still be placed. eBuy shall be used as one method to ensure at least three written quotations are received. If fewer than three are received, the Contracting Officer must document the file as to the actions taken to ensure competitive quotations, and what can be done in future acquisitions to enhance competition.

NUTS AND BOLTS TIP

Schedule contractors are not required to pass on to all GSA Schedule users a one-time spot price reduction provided to a single agency.

NUTS AND BOLTS TIP

FAR 9.405-1(b) prohibits ordering from any Schedule contractor that is debarred, suspended, or proposed for debarment unless the agency head makes a written determination of the compelling reasons for such action.

A Schedule user can review the contractor’s information page in GSA eLibrary (www.gsaelibrary.gsa.gov) or the Excluded Parties List System (EPLS) (www.epls.gov) to determine whether the prospective contractor is debarred, suspended, or proposed for debarment.