Federal contracting officers will have more competition requirements to think about starting May 16 when placing orders under the General Services Administration schedules.

Under a new interim rule published March 16 and effective two months later, contracting officers must distribute a request for quote for a planned procurement worth more than the simplified acquisition threshold that's to be made under the schedules to a sufficient number of vendors to "reasonably ensure" that at least three schedule holders capable of fulfilling the requirements respond with an offer.

Or, contracting officers can simply post the RFQ onto GSA's e-Buy system, where the quote is visible to all schedule holders selling pertinent products or services (i.e., those with the relevant special item number). If a contracting officer doesn't post the RFQ onto e-Buy, and doesn't obtain three quotes, then he must make a written determination that "clearly explains[s] efforts made to obtain quotes."

The simplified acquisition threshold is currently $150,000; the threshold is subject to potential revision every five years and was last increased in 2010.

For orders worth less than the simplified acquisition threshold, but more than the micro-purchase threshold (currently $3,000 under ordinary circumstances for products), it'll still be enough for a contracting officer to merely look at the price or catalog lists of three GSA vendors, or to send out the RFQ to three vendors and not be bothered about whether all three respond.

The GSA competition portion of the interim rule specifically affect Parts 8.405-1 and 8.405-2 of the Federal Acquisition Regulation.

The rule also establishes an official preference for multiple award blanket purchase agreements when done through the GSA schedules. Starting May 16, any anticipated BPA worth more than the simplified acquisition threshold will need to become the subject of a request for quote either posted onto e-Buy or distributed to enough companies such that at least three respond with quotes.

In fact, without a waiver from the agency head, BPAs worth more $103 million must be multiple award, the new rule states. As for ordering activity among the multiple holders of a BPA slot, they'll be subject to a kind of fair opportunity process, under which contracting officers must provide a request for quote to all BPA holders for any planned acquisition worth more than the simplified acquisition threshold. The new language affecting BPAs will be found in FAR Part 8.405-3.

The fair opportunity process for indefinite delivery, indefinite quantity contract vehicles also gets a revision under the interim rule. The new requirement will be for contracting officers to notify all IDIQ contract holders of an opportunity worth more than the simplified acquisition threshold. Until May 16, the rule has been that companies had to be notified only of every order opportunity worth more than $5 million. The new rule will affect FAR Part 16.505.

The interim rule's authority comes in large part from the fiscal 2009 Defense authorization bill and has been long-expected among the sort of people who pay attention to federal acquisition regulations, whether professionally or for fun.

The rule is not final, meaning that the public can submit comments about it--they are being accepted through May 16.

For more:
- download the interim rule as published in the Federal Register (.pdf)

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