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GSA Schedules, Special Ordering Provisions

By formerfed on Wednesday, March 28, 2001 - 07:55 am:

Several weeks ago, a debate occurred on this forum on placing orders under GSA Schedule. I couldn't find the thread but the argument concerned an audit of proper schedule use. The audit found that most of the orders examined failed to follow proper procedures established for that schedule by GSA. Some felt the confusion stemmed from GSA changing the rules and not providing enough notice. Also, some said they didn't see how GSA can impose rules different from what the FAR contains.

I just saw this from part 8.402 of the FAR.
8.402 Applicability.
Procedures in this subpart apply to orders placed against Federal Supply Schedules. Occasionally, GSA may establish special ordering procedures. The affected Federal Supply Schedules will outline these procedures.

Then I went to the schedule ordering provisions for services that require a Statement of Work. The ordering instructions begin by saying they are issued as special procedures and take precedent over what is contained in FAR 8.404 (b)(2) through (b)(3).

So it's clear that the GSA issued instructions are the same as regulations. It's too bad COs don't have a better way of being informed.

By Anonymous on Wednesday, March 28, 2001 - 10:32 am:

The audit failed to mention that the procedures were not in place until relatively recently. In addition, some of the schedules issued by schedule holders did not repeat the procedures correctly; know of one which stated that the Ordering Office should simply look at three schedules and place the order (which would be correct for products, but not for services).

More pressing question is if we will get procedures for purchasing from the Schedules if there is, for all practical purposes, a "sole source" sitatuation (unique qualifications or sometimes, follow-on tasks). Present guidance appears to be that thou shall not use GSA schedules for sole source buys; so, even in the face of a sole source situation (especially with follow-on orders) you send a task request to at least three vendors.

By Anon2 on Wednesday, March 28, 2001 - 01:17 pm:


"Schedule holders" do not issue schedules. GSA publishes schedules. Until relatively recently, service schedules did not include the special ordering procedures. I believe that new ones do. In any event, based on the FAR reference provided by formerfed the procedures do not have to appear in the schedules to be binding on agencies.

I doubt that GSA will authorize the issuance of sole source orders against schedules, but I don't know. In my opinion, the current procedure lets an agency order from just about anybody on the schedule. The problem is that in order to get to its preferred vendor an agency must conduct a sham competition.

By John Ford on Thursday, March 29, 2001 - 04:52 pm:

Anon2, please look at the last sentence in the extract from the FAR provided by Formerfed. Based on that sentence, is it still your position that "the affected Schedules" do not have to contain the special ordering procedures?
Another problem is that GSA has been changing the special ordering procedures as time passes. This has resulted in some schedules containing special ordering procedures which are different from the procedures published on the GSA Website. Question, in that case, which set of procedures takes precedence?

By Anon2 on Thursday, March 29, 2001 - 07:24 pm:

John Ford:

I don't know. The FAR says that GSA may establish special procedures and that the schedules will "outline" these procedures. I have to admit that I don't know what "outline" means exactly. I suppose you would say that "outline" means COs don't have to follow any procedure that's not in a schedule. I wouldn't devote a lot of time to arguing with you about that. It looks like GSA plans to put the special ordering procedures in FAR Part 8, so the question will probably be moot sometime later this year.

By Loki on Wednesday, April 11, 2001 - 11:30 am:

It's tough to get a schedule contract copy from GSA. Their 1102s refer you to the contractors instead.

By Loki on Thursday, April 12, 2001 - 11:13 am:

What was the name of that other thread? I believe there were some case law citations there that I'd like to research.?

I'm curious if Cybertech/00-768 C was discussed therein.

By FF on Monday, May 07, 2001 - 11:26 am:

Todays Federal Computer Week has some interesting information on this subject. Professional services account for 53% of Schedule revenue; Schedule business grew from $1.2 billion in 1998 to $5.5 billion last year; and a GSA study showed that agencies place orders under Schedule in 1/4 the time for open market acquisitions. So any drastic changes to the process will have major impact throughout the Government. For starters, GSA obtains funding from each order placing. Curtailing this revenue translates to severe financial harm to GSA and their staff. On the agency/customer side, most take for granted that new orders for unplanned needs can happen quickly. If the rug suddenly gets pulled, that can hurt. This will be something to watch.

By Anonymous on Monday, May 07, 2001 - 12:50 pm:

If you click on topics to the left when the window opens click on contracts general discussion scroll to the bottom and the fourth from the bottom is where the thread can be found.

By Anonymous on Tuesday, May 08, 2001 - 08:17 am:

Check out article in yesterday's Washington Post, which included quote from Schedule 70 (IT) firm Chairman, who referred to GSA schedules as "hunting license" for contractors to market themselves.