Office of Procurement, Acquisition and Logistics (OPAL)

Ordering Procedures for Orders Not Requiring a Statement of Work

These ordering procedures apply to orders placed under the following Schedule programs (as identified in FAR 8.4):

• 65IB Drugs, Pharmaceuticals, & Hematology Related Products
• 65IIA Medical Equipment & Supplies
• 65IIC Dental Equipment & Supplies
• 65IIF Patient Mobility Devices
• 65VA X-Ray Equipment & Supplies
• 65VII Invitro Diagnostics, Reagents, Test Kits & Test Sets
• 66III Cost-Per-Test, Clinical Laboratory Analyzer

The use of the above Schedules is mandatory for VA ordering activities.

As well as the 621II Medical Laboratory Testing & Analysis Services.  The use of this Schedule is non-mandatory for VA ordering activities.

Ordering Procedures

FAR 8.4, Federal Supply Schedules, was updated May 16, 2011, to include Section 863 of the Fiscal Year 2009 Duncan Hunger National Defense Authorization Act (NDAA); this rule enhances competition requirements for orders placed against multiple-award contracts.

Orders at or below the micropurchase threshold ($3,000)

For orders valued at or below the micropurchase threshold, ordering activities shall

1. Place the order with any Schedule contractor that meets the agency’s need
2. Seek to even distribute orders among Schedule contractors

Orders between the micropurchase threshold and the simplified acquisition threshold ($150,000)

For orders valued between the micropurchase threshold and the simplified acquisition threshold, ordering activities shall

1. Consider reasonably available information about at least three (3) Schedule contractors that meet the agency’s need.  Comply with FAR 8.405-6, Limiting Sources, as applicable.  Schedule contractor information is readily available via
   • The contractor’s Authorized FSS Paper Price List (request a copy from the contractor);
   • The Contract Catalog Search Tool;
   • GSA eLibrary
   • GSA Advantage!
2. You may also request a quote from at least three (3) Schedule contractors.
3. Place order with the contractor that represents the best value.

Orders over the simplified acquisition threshold ($150,000)

For orders valued over the simplified acquisition threshold ($150,000), ordering activities shall

1. Develop an RFQ in accordance with FAR 8.405-1(d).
2. Give all Schedule contractor holders fair notice and the opportunity to respond.  GSA eBuy meets the standard of providing “fair notice to all contractors” because all vendors offering the required supplies and/or services are able to view the Request for Quote.  If you do not use eBuy or another means of providing fair notice, you must distribute the RFQ by some other means and receive at least three (3) quotes.
3. Comply with FAR 8.405-6, Limiting Sources, as applicable.
4. Ensure all quotes are considered fairly and award is made in accordance with basis for selection and to contractor that represents the best value.

Priorities of Use for Government Supply Sources

Visit the Priorities of Use for Government Supply Sources page for a complete listing of VA priorities (as outlined in VAAR 808.002 and standard priorities of use for government supply sources).

Adding Clauses & Provisions to an RFQ

Nothing in the FAR or in the Schedule contract prohibits ordering agencies from adding non-conflicting clauses from the FAR or agency supplements to Schedule orders or BPAs.  You may have to add clauses as required by your local ordering procedures.

Non-Conflicting Clause:

• An added FAR or agency clause that does not contradict a Schedule contract clause
• An added FAR or agency clause without a usage limiting it to non-commercial acquisitions or where the clause usage does not prohibit the clause in a commercial acquisition
• An added FAR or agency clause that is consistent with customary commercial practice (or for which a waiver has yet to be granted)

Adding a clause typically addressed at an IDIQ contract, especially in pricing, could possibly conflict with the awarded terms and conditions of a Schedule contract.

Option Periods

Option periods may be included in the RFQ if they are clearly stated in requirement and evaluated as part of the ordering activity’s best value determination.

Options may be exercised if:

• Funds are available
• The requirement covered by the option fulfills an existing government need
• Prior to exercising the option, the ordering activity ensures that it is still in the government’s best interest
• Options do not extend beyond the period of the Schedule contract, including option year periods.

Required Documentation

You are required to document:

• The Schedule contracts considered, noting the awarded contractor
• Full description of the services purchased
• Actual amount paid
• If total amount paid exceeds the SAT, evidence of compliance with FAR 8.405-2(c)
• Basis for the award decision

Other Responsibilities

Ordering activities are required to

• Conduct compliance checks, including System for Award Management (SAM)
• Submit a performance evaluation through Contractor Performance Assessment Reporting System (CPARS) (for orders over the SAT)
• Notify unsuccessful contractors (optional)

Best Practices

1. Each order shall be placed on a competitive basis.
2. Prepare an RFQ that includes a description of the supplies to be delivered or services to be performed and the basis for selection.
3. Post the RFQ to GSA e-Buy or provide to as many Schedule contractors as practicable.
4. Ensure that all quotes received are fairly considered and award is made in accordance with the basis for selection as outlined in the RFW.
5. Review Contract Catalog Search Tool; GSA eLibrary; GSA Advantage! and contractors Authorized FSS Paper Price List when conducting market research and making a best value selection.
6. Ordering activities may consider socioeconomic status when identifying contractor(s) for consideration or competition for award of an order.
7. Orders exceeding the maximum order may be placed even if the contractor does not provide additional price reductions or discounts.  Visit the VA Schedule Programs page for a complete listing of maximum orders by SIN categories.

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