What is a Blanket Purchase Agreement (BPA)?

What is a Blanket Purchase Agreement (BPA)?

A BPA, or Blanket Purchase Agreement, is a “funnel” to narrow competition to a few GSA Schedule (or VA FSS) Contractors. Per the Federal Acquisition Regulation 8.405-3 it is designed to fill the Government’s recurring needs for a Government contractor’s specific goods or services. The contractor benefits from limited competition and the Government benefits from additional discounts and less administrative effort. Government buyers need not spend time searching for appropriate sources and the streamlined competitive nature means faster turnaround times. If you look at the historical performance of GSA Schedule holders, you will note that some of the most lucrative GSA contracts rely heavily on BPA purchases.

Where to Find BPAs


Coronavirus Relief Options for Small Businesses

Coronavirus Relief Options for Small Businesses

Recently, much has been written regarding Coronavirus relief options for small businesses through traditional SBA funding and several new temporary programs established by the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Important information about each program including the application process and qualifications can be found on the SBA’s website here.

The two primary relief options are the Economic Injury Disaster Loan (EIDL) Emergency Advance and the Paycheck Protection Program. Both programs are loan options and contain the possibility of forgiveness. Both programs also have restrictions on how the loan may be used. See SBA for more information on use requirements.

EIDL allows small businesses to receive a loan of up to $2 million ($25,000 unsecured) with an available grant advance of up to $10,000. This loan will be automatically deferred for 12 months with a term of up to 30 years and an interest rate of 3.75%. EIDL eligibility includes: 

  • Small Businesses started before January 31, 2020 Small Businesses (under 500 employees)
  • Sole Proprietors (under 500 employees)
  • Independent Contractors
  • Self-Employed Persons
  • Cooperatives (under 500 employees)
  • Employee Stock Ownership Plan (ESOP) (under 500 employees)
  • Tribal small business (under 500 employees)
  • Agricultural cooperative, aquaculture enterprise, nursery, or producer cooperative (under 500 employees)
  • Business with more than 500 employees but under SBA Size Standards
  • Private non-profit organization with IRS designation 501(c),(d), or (e) OR State evidence is a non-profit one organized or doing business under State law, or a faith-based organization. 

The Paycheck Protection Program is designed to provide up to 8 weeks of payroll and other business expenses. Loans may be requested for up to $10 million. Loan will be deferred for six months with a two-year repayment term and 1% interest rate. Loan eligibility requirements include: 

  • Small Businesses started before February 15, 2020
  • Any small business concern that meets SBA’s size standards (either the industry based sized standard or the alternative size standard)
  • Any business, 501(c)(3) non-profit organization, 501(c)(19) veteran organizations, or Tribal business concern (sec. 31(b)(2)(C) of the Small Business Act) with the greater of: 500 employees, or
  • That meets the SBA industry size standard if more than 500
  • Any business with a NAICS Code that begins with 72 (Accommodations and Food Services) that has more than one physical location and employs less than 500 per location
  • Sole proprietors, independent contractors, and self-employed persons 

Loan Forgiveness

In regard to the PPP, the loan will be fully forgiven if the funds are used for payroll costs, interest on mortgages, rent, and utilities (due to likely high subscription, at least 75% of the forgiven amount must have been used for payroll). Forgiveness is based on the employer maintaining or quickly rehiring employees and maintaining salary levels.  Forgiveness will be reduced if full-time headcount declines, or if salaries and wages decrease. To apply for loan forgiveness each recipient should be prepared to submit a written request to your lender. The lender will have 60 days to reply. The written request should include documents verifying full time equivalent employees, employee pay rates, payments on eligible mortgage, payments on eligible lease, and payments on utilities.

Forgiveness regarding the EIDL Emergency Advance program is limited to the grant advance itself of up to $10,000 which must be used for prescribed business expenses.

During the rollout of these programs, one thing is clear. No one has all the answers. There is a great deal of confusion regarding the two most talked about programs the EIDL Emergency Advance and the Paycheck Protection Program (PPP). Please keep in mind that available information is changing rapidly and is often based on the current understanding or interpretation of these programs. It can and likely will continue to change. Rather than speculate as to the answers to some of the more difficult questions surrounding each program, a better approach is to focus on some practical steps you can take to help these programs work for your business most effectively. 

First, Get Educated 

Consult with your lawyers, CPAs, Bankers and Financial Advisors regarding these programs as soon as you are able. There are daily webinars put on by various groups including local and regional SBA offices, Chamber of Commerce groups, CPA firms, Banks and Law firms. One excellent way to engage the latest information about these programs is through social media. Many local and regional SBA offices are very active relaying educational opportunities and available information via their official twitter accounts.

Do Not Delay

Once you have identified a broad understanding of how these programs may help your business DO NOT DELAY. The PPP for small businesses was made available April 3rd and many have already submitted applications. Independent Contractors and Self-Employed Individuals may begin applying April 10th, 2020.

Make sure that you are being proactive in applying as soon as you can if you have not already applied. The EIDL Emergency Advance application can be found on the SBA’s website here.

For the PPP, you will need to apply through a bank or credit union. The SBA and others are recommending, if possible, you work with a banker that you have an existing banking relationship with. You can find eligible lenders here.

Organization is Key

Having strong paper and digital business records will help you tremendously during the application process but also be vigilant about keeping records during and after the loan application process as well. It is important to ask lots of questions, take good notes and get any clarification in writing. It is confirmed that businesses will be asked to provide their NAICS code and DUNs number as part of the application process. These can easily be accessed by Coley customers here under the Entity Dashboard.

Follow Up

Be patient but not too patient. Throughout the rollout of these programs, it is clear the timing of funding is delayed. It is also clear that the businesses that have followed the steps laid out above will have the most success. Regarding the EIDL Emergency Advance and the Paycheck Protection Program, it may be necessary to engage daily. The SBA has determined that the loans will be distributed on a first come first served basis. Do not be afraid to regularly follow up with the SBA and/or your Banker directly. The adage “The squeaky wheel gets the grease” certainly applies here. Again, it is prudent to utilize the social media accounts of local and regional SBA offices, Chamber of Commerce groups, CPA firms, Banks and Law firms for the latest updates, information, and interpretations of these programs.

Are Other Programs a Better Option for Your Business?

Do not overlook the lesser talked about SBA Express Bridge Loans and SBA Debt Relief programs. For those that qualify, there is evidence that these programs applications are being processed more quickly, simply because they have been less utilized during the Coronavirus event. For example, for businesses that qualify, the SBA Express Bridge Loan may be a more efficient and more realistic program to quickly access funds as an alternative to the EIDL  that is currently plagued with delays and confusion. Specifics about this program can be found here.

Seeking debt relief instead of a new loan from a program like the Paycheck Protection Program may be an option for many small businesses. The SBA Debt Relief program may be an excellent choice for those businesses that already have current SBA 7(a), 504 or microloans. More specific information about this program can be found here.

Additionally, there are some general indications that businesses that qualified for SBA funding before the expansion of the qualifications under the recent CARES Act may have an advantage in tapping these resources most effectively. Businesses with an existing relationship with the SBA or businesses with a profile familiar to the SBA could experience smoother application processes across the board. More information about one such qualifying business, SBA 7(a), can be found here.

One Last Important Tip for Our Coley Customers – Action Item! 

Business owners around the country may have recently had their identities compromised through the SBA website intended to help them during the Coronavirus event. There is no confirmation yet on how many business owners could have been exposed; the SBA is only saying a “limited number”. One thing is for sure, if you feel you may have been exposed, it is paramount that you take action now. The SBA disaster relief loan application process requires both a personal and business credit check. For small business owners, there is currently no mechanism for freezing a business credit file. Normally a personal credit freeze would be appropriate if you believe you have been compromised, but a freeze now could delay or hinder your ability to complete personal identity verifications and personal credit checks required for the SBA disaster funding opportunities. So, what should you do? Diligently monitor your personal and business credit to protect your identity against potential fraud. There are indications that fraud has increased since the Coronavirus event with reports of increased phishing scams, fraud-focused phone calls and even app stores flooded with data-leaking apps specifically targeting small businesses seeking SBA loans under the new programs Credit monitoring services are offered through the 3 major credit bureaus as well as other commercial providers.

Coley GCS will continue to monitor and will publish more updates as they become available.



A List of TAA Designated Countries

A List of TAA Designated Countries

What is TAA Compliance?

(Updated: June 2019 )

How do you know if you are TAA Compliant? TAA refers to the Trade Agreement Act. Under 19 USC 2501 Trade Agreements Act government agencies may only purchase US-made or designated country end products or US or designated country services.

Are Your Products on GSA Schedule TAA Compliant?

Because the estimated value of a GSA schedule exceeds $191,000, all GSA product sales must be Trade Agreement Act (TAA) compliant, as per FAR 52.225-5. In order to be TAA compliant, Customs and Border Protection (CBP) considers either that 50 percent of the cost of manufacture or location where product is “substantially transformed” is from/within a TAA Designated Country.

If you offer services through your GSA Schedule, the TAA may also apply to you; but that is not always the case. The issue of how the TAA applies to services is a complex one.

How to Determine if products were “Substantially Transformed?”

If a product is completely manufactured in the United States or in a TAA designated country, you are TAA compliant. Software country of origin is determined in the country where the software was compiled.

Sometimes a product requires assembly in several countries or has components from various countries; the TAA compliance becomes murkier and a determination of where the product is substantially transformed is required. If a product is manufactured in various countries, the final product must be “substantially transformed” in a designated country. Substantial transformation would be transforming an article into a new and different article of commerce, with a name, character, or use distinct from the original article. (refer to FAR 25.001(c))

Responsibility falls wholly on the government contractor, to determine if a product has been substantially transformed. More information on International Trade: Rules of Origin available here: http://www.fas.org/sgp/crs/row/RL34524.pdf.

Who Makes the Determination of TAA Compliance?

The U.S. Customs and Border Protection states that “the responsibility for making a determination of substantial transformation rests solely with the contractor. The contractor can go to The Office of Regulations and Rulings within U.S. Customs and Border Protection, which is the Federal agency responsible for making substantial transformation determinations or giving their opinions.”

How to Keep Your GSA Schedule TAA Compliant?

First you must have a system in place that periodically verifies that the products being offered under your GSA schedule are TAA compliant. Furthermore, if you are not a manufacturer, we recommend that you verify countries of origin quarterly or, at minimum, with catalog updates from your suppliers to verify that products are still being manufactured or “substantially transformed” in a TAA designated country.

If your manufacturing source changes during the term of your contract and items are now manufactured in a non-designated country, your products will consequently be out of compliance. You must immediately take action to remove the non-TAA compliant items from your GSA Schedule. A GSA consultant from the Coley team can assist with getting this processed.

TAA Designated Countries are regularly updated and can be accessed from here:  FAR-Clause-52.225-5. Also, as noted on our table below, if a product is manufactured in China, Indonesia, Malaysia, or Sri Lanka, you may be permitted to sell them, but only to the VA with a required waiver. Territories belonging to the United States, are TAA compliant therefore, American Samoa, Northern Mariana Islands, Puerto Rico, and the United States Virgin Islands are compliant countries.

Current List of TAA Compliant Countries Include:


Afghanistan Denmark Latvia Sao Tome and Principe
Angola Djibouti Lesotho Senegal
Antigua and Barbuda Dominica Liberia Sierra Leone
Armenia Dominican Republic Liechtenstein Singapore
Aruba El Salvador Lithuania Sint Eustatius
Australia Equatorial Guinea Luxembourg Sint Maarten
Austria Eritrea Madagascar Slovak Republic
Bahamas Estonia Malawi Slovenia
Bahrain Ethiopia Mali Soloman Islands
Bangladesh Finland Malta Somalia
Barbados France Mauritania South Sudan
Belgium Gambia Mexico Spain
Belize Germany Moldova* Saint Kitts and Nevis
Benin Greece Montenegro Saint Lucia
Bhutan Grenada Montserrat Saint Vincent and the Grenadines
Bonaire Grenadines Morocco Sweden
British Virgin Islands Guatemala Mozambique Switzerland
Bulgaria Guinea Nepal Taiwan
Burkina Faso Guinea Bissau Netherlands Tanzania U.R.
Burundi Guyana New Zealand Timor- Leste (East Timor)
Cambodia Haiti Nicaragua Togo
Canada Honduras Niger Trinidad & Tobago
Central African Republic Hong Kong Norway Tuvalu
Chad Hungary Oman Uganda
Chile Iceland Panama Ukraine*
Colombia Ireland Peru United Kingdom
Comoros Israel Poland **United States of America
Democratic Republic of the Congo Italy Portugal Vanuatu
Costa Rica Jamaica Romania Yemen
Croatia Japan Rwanda Zambia
Curacao Kiribati Saba
Cyprus Korea, Republic of (South)
Czech Republic Laos

**Includes all US Territories: Puerto Rico, US. Virgin Islands, Guam, American Samoa and Northern Mariana Islands.


Non-TAA Compliant Countries List Below:

*FAR 52.225-5 (Reviewed: June 2019); Federal Acquisition Regulation , Trade Agreements.


Albania Georgia Marshall Islands Seychelles
Algeria Ghana Mauritius Sri Lanka
Argentina India Micronesia Sudan
Azerbaijan Indonesia Monaco South Africa
Belarus Iran Mongolia Suriname
Bolivia Iraq Myanmar Swaziland
Bosnia and Herzegovina Jordan Namibia Syria
Botswana Kazakhstan Nauru Tajikistan
Brazil Kenya Nigeria Thailand
Brunei Darussalam Korea, North Pakistan Tonga
Cameroon Kosovo Palau Tunisia
Cape Verde Kuwait Papua New Guinea Turkey
China Kyrgyzstan Paraguay Turkmenistan
Cote d’Ivoire Lebanon Philippines United Arab Emirates
Cuba Libya Qatar Uruguay
Ecuador Macao Republic of Congo Uzbekistan
Egypt Macedonia Russia Venezuela
Fiji Malaysia Saudi Arabia Vietnam
Gabon Maldives Serbia Zimbabwe


VA only – Waiver Required

The VA is in charge of the healthcare related Federal Supply Schedules (FSS.)There may be some instances where certain healthcare related products needed to save lives are only manufactured in non-TAA compliance countries including China. You must obtain a TAA Waiver from a Contracting Officer before you can add any non-TAA compliant products to your Schedule. The letter must state that the product is necessary and that they are providing a waiver of the TAA for a particular contract or task order.

The VA is currently processing Non-Availability Waiver Determinations under the VA’s 65 I B Pharmaceutical and Drugs Schedule program.  Furthermore, these waiver requests can only be processed for products falling under the scope of Special Item Number 42-2A Single source drug, innovator multiple source drug, and any biological product identified under Section 600.3 of Title 21, CFR.


China Indonesia Malaysia
Sri Lanka Thailand

World Trade Organization
GSA Vendor Support
VA – Office of Acquisition and Logistics  
FAR 25. 4 Acquisition.gov  
FAR 25.225-5 Acquisition.gov
Harmonized Tariff Schedule of the United States


*FAR Case 2016-009; New Designated Countries Effective as of October 31, 2016 for Moldova and Ukraine

52.225-5 Trade Agreements.

As prescribed in 25.1101(c)(1), insert the following clause:

Trade Agreements (Feb 2016)

(a) Definitions. As used in this clause—

“Caribbean Basin country end product”—

(1) Means an article that—

(i)    (A) Is wholly the growth, product, or manufacture of a Caribbean Basin country; or

(B) In the case of an article that consists in whole or in part of materials from another country, has been substantially transformed in a Caribbean Basin country into a new and different article of commerce with a name, character, or use distinct from that of the article or articles from which it was transformed; and

(ii) Is not excluded from duty-free treatment for Caribbean countries under 19 U.S.C. 2703(b).

(A) For this reason, the following articles are not Caribbean Basin country end products:

(1) Tuna, prepared or preserved in any manner in airtight containers;

(2) Petroleum, or any product derived from petroleum;

(3) Watches and watch parts (including cases, bracelets, and straps) of whatever type including, but not limited to, mechanical, quartz digital, or quartz analog, if such watches or watch parts contain any material that is the product of any country to which the Harmonized Tariff Schedule of the United States (HTSUS) column 2 rates of duty apply (i.e., Afghanistan, Cuba, Laos, North Korea, and Vietnam); and

(4) Certain of the following: textiles and apparel articles; footwear, handbags, luggage, flat goods, work gloves, and leather wearing apparel; or handloomed, handmade, and folklore articles;

(B) Access to the HTSUS to determine duty-free status of articles of these types is available at http://www.usitc.gov/tata/hts/. In particular, see the following:

(1) General Note 3(c), Products Eligible for Special Tariff treatment.

(2) General Note 17, Products of Countries Designated as Beneficiary Countries under the United States-Caribbean Basin Trade Partnership Act of 2000.

(3) Section XXII, Chapter 98, Subchapter II, Articles Exported and Returned, Advanced or Improved Abroad, U.S. Note 7(b).

(4) Section XXII, Chapter 98, Subchapter XX, Goods Eligible for Special Tariff Benefits under the United States-Caribbean Basin Trade Partnership Act; and

(2) Refers to a product offered for purchase under a supply contract, but for purposes of calculating the value of the acquisition, includes services (except transportation services) incidental to the article, provided that the value of those incidental services does not exceed that of the article itself.

“Designated country” means any of the following countries:

(1) A World Trade Organization Government Procurement Agreement (WTO GPA) country (Armenia, Aruba, Austria, Belgium, Bulgaria, Canada, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hong Kong, Hungary, Iceland, Ireland, Israel, Italy, Japan, Korea (Republic of), Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Montenegro, Netherlands, New Zealand, Norway, Poland, Portugal, Romania, Singapore, Slovak Republic, Slovenia, Spain, Sweden, Switzerland, Taiwan (known in the World Trade Organization as “the Separate Customs Territory of Taiwan, Penghu, Kinmen and Matsu (Chinese Taipei)”), or United Kingdom);

(2) A Free Trade Agreement (FTA) country (Australia, Bahrain, Canada, Chile, Colombia, Costa Rica, Dominican Republic, El Salvador, Guatemala, Honduras, Korea (Republic of), Mexico, Morocco, Nicaragua, Oman, Panama, Peru, or Singapore);

(3) A least developed country (Afghanistan, Angola, Bangladesh, Benin, Bhutan, Burkina Faso, Burundi, Cambodia, Central African Republic, Chad, Comoros, Democratic Republic of Congo, Djibouti, Equatorial Guinea, Eritrea, Ethiopia, Gambia, Guinea, Guinea-Bissau, Haiti, Kiribati, Laos, Lesotho, Liberia, Madagascar, Malawi, Mali, Mauritania, Mozambique, Nepal, Niger, Rwanda, Samoa, Sao Tome and Principe, Senegal, Sierra Leone, Solomon Islands, Somalia, South Sudan, Tanzania, Timor-Leste, Togo, Tuvalu, Uganda, Vanuatu, Yemen, or Zambia); or

(4) A Caribbean Basin country (Antigua and Barbuda, Aruba, Bahamas, Barbados, Belize, Bonaire, British Virgin Islands, Curacao, Dominica, Grenada, Guyana, Haiti, Jamaica, Montserrat, Saba, St. Kitts and Nevis, St. Lucia, St. Vincent and the Grenadines, Sint Eustatius, Sint Maarten, or Trinidad and Tobago).

“Designated country end product” means a WTO GPA country end product, an FTA country end product, a least developed country end product, or a Caribbean Basin country end product.

“End product” means those articles, materials, and supplies to be acquired under the contract for public use.

“Free Trade Agreement country end product” means an article that—

(1) Is wholly the growth, product, or manufacture of a Free Trade Agreement (FTA) country; or

(2) In the case of an article that consists in whole or in part of materials from another country, has been substantially transformed in an FTA country into a new and different article of commerce with a name, character, or use distinct from that of the article or articles from which it was transformed. The term refers to a product offered for purchase under a supply contract, but for purposes of calculating the value of the end product includes services (except transportation services) incidental to the article, provided that the value of those incidental services does not exceed that of the article itself.

“Least developed country end product” means an article that—

(1) Is wholly the growth, product, or manufacture of a least developed country; or

(2) In the case of an article that consists in whole or in part of materials from another country, has been substantially transformed in a least developed country into a new and different article of commerce with a name, character, or use distinct from that of the article or articles from which it was transformed. The term refers to a product offered for purchase under a supply contract, but for purposes of calculating the value of the end product, includes services (except transportation services) incidental to the article, provided that the value of those incidental services does not exceed that of the article itself.“United States” means the 50 States, the District of Columbia, and outlying areas.

“U.S.-made end product” means an article that is mined, produced, or manufactured in the United States or that is substantially transformed in the United States into a new and different article of commerce with a name, character, or use distinct from that of the article or articles from which it was transformed.

“WTO GPA country end product” means an article that—

(1) Is wholly the growth, product, or manufacture of a WTO GPA country; or

(2) In the case of an article that consists in whole or in part of materials from another country, has been substantially transformed in a WTO GPA country into a new and different article of commerce with a name, character, or use distinct from that of the article or articles from which it was transformed. The term refers to a product offered for purchase under a supply contract, but for purposes of calculating the value of the end product includes services, (except transportation services) incidental to the article, provided that the value of those incidental services does not exceed that of the article itself.

(b) Delivery of end products. The Contracting Officer has determined that the WTO GPA and FTAs apply to this acquisition. Unless otherwise specified, these trade agreements apply to all items in the Schedule. The Contractor shall deliver under this contract only U.S.-made or designated country end products except to the extent that, in its offer, it specified delivery of other end products in the provision entitled “Trade Agreements Certificate.”

(End of clause)

What is Best Value Source Selection

What is Best Value Source Selection

FAR 15.1 covers Source Selection Process and Techniques. FAR 15.101 covers the Best Value Continuum which provide guidance on when agencies should consider the Tradeoff process (Best Value) or Lowest Priced Technically Acceptable (LPTA) Source Selection.

Best Value should always be used when the deliverable requirements are not clearly defined, and there may be a risk of contractor performance. The tradeoff process allows tradeoffs between price and non-price factors, the tradeoff should justify the tradeoff in price.

The selection committee or contracting officer will determine if tradeoff process is appropriate and when that decision is made, the following apply:

  • All evaluation factors and significant subfactors that will affect contract award and their relative importance shall be clearly stated in the solicitation; and
  • The solicitation shall state whether all evaluation factors other than cost or price, when combined, are significantly more important than, approximately equal to, or significantly less important than cost or price.

When the tradeoff process is used, pay specific attention to the evaluation factors and how those items are evaluated. If you are unsuccessful in your bid, when appropriate, request a full debriefing.

Recently, John S. McCain National Defense Authorization Act for Fiscal Year 2019 made sweeping federal changes that limit the use of LPTA, especially on complex professional and IT solutions. These restrictions should increase the number of best value opportunities available, See our blog here.

What is Lowest-Priced Technically Acceptable Source Selection

What is Lowest-Priced Technically Acceptable Source Selection

The scourge of many professional service providers is the lowest priced technically acceptable (LPTA) source selection process. FAR 15.101-2 address LPTA source selection.

Product vendors, especially those acted as resellers of widely available products, should understand that nearly all of their federal opportunities will be price sensitive and value will likely not be considered. (more…)

What are Sole Source Contracts?

What are Sole Source Contracts?

Sole Source Contracts are non-competitive procurements that allow a single supplier to fulfill the needs of the contractual requirements. Though Full and Open Competition is preferred in federal acquisitions, the use of a sole source can be highly valuable when specific circumstances are met. Sole-Source acquisitions are detailed in the Federal Acquisition Regulation (FAR) parts 6 and 13; aspects of the sole-source award process include an exigent need, limited source of supply or service, brand-name justification, and/or competition is determined inadequate. In most cases, Sole Sourcing is the result of competitive proposals being not applicable to the contract requirements.

How Are Sole Sources are Awarded?

Sole source awards can be made to vendors when one or more of three criteria are met.

  • The item/service is available only from one source (Brand Name Justification).
  • The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation.
  • Competition is determined inadequate after solicitation of a number of sources.

Justification an Approval (J&A)

Sole source awards require contracting officer to complete written justifications for approval when considering a sole source contract.  It is important for vendors to arm contracting officers with the information that need to help to make this justification. The requester will provide circumstances for approval with applicable supportive information. These criteria include:

  • Description of the project and amount to be designated for the contract
  • Explanation of necessity to contract from one source:
    • Descriptions of unique aspects in which eliminates competition. Such as unique capability, expertise, facilities or equipment that no other source can provided.
    • Verifying that such aspects are indeed only available through the one source.
    • If this is an urgent timing matter, such as emergencies that will have a significant effect, please provide the descriptions of deadlines, impacts of deadlines and the need for the timely contract.
  • If there are competitors, explanation of how long they would take to complete the same task
  • Results of a Market survey determining the inadequate competition
  • Declaration that this sole source procurement is in the best interest of the agency.

Sole Source Thresholds

Here are a few tips to remember when purchasing lobbying for a sole source. Every purchase that goes over the Micro-Purchase Threshold of $10,000 (or $3,500 for DOD), a justification will be required, unless the purchase is from an existing contract, the supplier is named in the opportunity or the purchase is being competitively solicited. The only exception for justification is consulting services.
When above the micro-purchase threshold, a
gencies have the authority to award Sole Source contract noncompetitive proposals but must meet extensive criteria for justification and approval. Sole Source justification must meet the following circumstances:

  • Written justification must be provided and approved specified in FAR based on value of acquisitions
    • Above the micro-purchase threshold, but below the simplified acquisitions threshold – contracting officer certification that acquisition is accurate and complete
    • Above the simplified Acquisition Threshold, but below $700,000 — contracting officer certification that acquisition is accurate and complete
    • Above $700,000, but not exceeding $13.5 million – the advocate for competition for the for the procurement activity or designated officer (see FAR 6.305) approval is required
    • Above $13.5 million, but below $68 million – head of the procuring activity of designated official (see FAR 6.305) approval is required
    • Above $68 million — by the senior procurement executive of the agency in accordance with agency procedure
  • Make the justification publicly available within 14 days after contract award, unless it is an unusual and compelling urgency, then 30 days after award

Sole Sourcing Denial

There will be situations where the Sole Source contract will not be accepted. This happens when there is more than one bidder or offeror for the one proprietary item, when an agency prefers a specific name branded product or at times, those aspect’s uniqueness alone will not be enough to be determined as a sole provider. In addition, the justifications can also result in disapproval if it is used to select a preferred vendor. This will lead to auditors digging for details to suggest a possibility of favoritism, partiality or other bias.


The benefits to a vendor are multiple, but you should understand the benefits to agencies as well to help negotiate the need for a sole source. Aside from a quicker acquisition process, other benefits include an efficiency increase on the administrative side with lowered production costs, fewer contracts to negotiate and, ideally, a better value for the prices. Product quality should improve as the delivery process will be more effective. Because of the short span from delivery to use, there may be quicker discoveries of any defective items. There will also be an opportunity to build a partnership with the supplier which could be very beneficial long term.

Please let Coley know if you have any questions on federal contracting or sole sources items. 

Introduction to The SBA’s Mentor-Protégé Program

Introduction to The SBA’s Mentor-Protégé Program

A Path to Government Contracting

One of the Small Business Administration’s mission is to continuously expand Federal contracting opportunities for Small Business. In 2016, they established the All Small Mentor-Protégé Program (ASMPP) to extend SBA approved mentor-protégé relationships to every small business. The program was designed to enhance the capability of the protégé firms to win Federal business utilizing the mentor company’s business development capabilities and substantive project experience. (more…)

What Products are Purchased Through BuyBoard?

What Products are Purchased Through BuyBoard?

Athletic, Physical Education Supplies and Equipment
Athletic clothing, shoes and uniforms, fitness equipment, gymnasium seating, scoreboards, washers and dryers

Auction Services (On-Line Only)
On-Line auction services for the disposal of surplus personal property and equipment (more…)

Fixing Federal Verification Co., Inc. Mistakes on GSA

If your GSA contract was awarded using the debarred Federal Verification Co., Inc or one of their 40 plus aliases, your contract may be at risk of non-compliance.  Names used include GSA Applications, GSA 1000, GSA Processors, GSA Alliance, Federal Suppliers Guide, Government Awards Consulting, and a variety of others.  A list of Alternate Business Names appears here.

GSA debarred this GSA consultant and has requested all affected contractors to update their schedule to remove these consultants from your schedule.

To complete this process, you must have at least one digital certificate associated with a company representative with signature authority.  If you (more…)

Validate Your ACES Business Representative Certificate with GSA

Digital Certificates: Don’t let this delay your success!

All GSA Schedule holders and new offerors who wish to do business with the GSA Federal Supply Schedule program must have a digital certificate to access various GSA systems that are essential for continued success.  These systems include the eOffer system (used to submit new offers to GSA), eMod (submitting contract modifications), and the new FAS Sales Reporting system used to submit your monthly FSS sales. (more…)

What is a CAGE Code?

What is a CAGE Code?

CAGE Code stands for Commercial and Government Entity code.

The Department of Defense’s Defense Logistics Agency, (DLA) assigns the five-character ID and uses alpha numeric identifier is assigned to entities located in the United States and its’ territories.


List of Agencies that Can Purchase from GSA Schedules

List of Agencies that Can Purchase from GSA Schedules

If you are a GSA Schedule holder, it is important to know who is eligible to purchase from your GSA Schedule as a source of supply and services and to know when to sell to your products at GSA Schedule prices. Being knowledgeable of GSA’s list of eligible ordering activities can keep you safe from infractions with the Price Reduction Clause of your contract while also making you aware of other potential GSA customers.

GSA provides a detailed list of authorized ordering activities. This list includes some obvious ordering activities such as executive agencies and departments but also some not so obvious ordering actives such as Tribes and government contractors. It is important to read this list and the condition of each ordering activities authority to make sure you fully understand their scope. The list of eligible ordering activities and their scope can be found here: http://www.gsa.gov/portal/mediaId/176231/fileName/SignedGSADirective48002H.action. The table below is an extract of their Appendices, however,  GSA makes clear: “This list is not all-inclusive; others may also be eligible to use GSA sources of supply and services.”

Executive Agencies

  • Advisory Council on Historic Preservation
  • Agency for International Development
  • Agriculture, Department of
  • Air Force, Department of
  • American Battle Monuments Commission
  • Armed Forces Retirement Home
  • Army Corp of Engineers
  • Army, Department of
  • Bonneville Power Administration
  • Bureau of Land Management
  • Central Intelligence Agency
  • Christopher Columbus Fellowship Foundation
  • Commerce, Department of
  • Commission on Civil Rights
  • Commission on Fine Arts
  • Commodity Credit Corporation
  • Commodity Futures Trading Commission
  • Consumer Products Safety Commission
  • Corporation for National and Community Service
  • Defense, Department of
  • Defense agencies and Joint Service Schools
  • Defense Nuclear Facilities Safety Board
  • Education, Department of
  • Energy, Department of Environmental Protection Agency
  • Equal Employment Opportunity Commission
  • Executive Office of the President
  • Export-Import Bank of U.S.
  • Farm Credit Administration
  • Federal Communications Commission
  • Federal Election Commission
  • Federal Emergency Management Agency
  • Federal Labor Relations Authority
  • Federal Maritime Commission
  • Federal Trade Commission
  • Forest Service, U.S.
  • General Services Administration
  • Government National Mortgage Association
  • Harry S. Truman Scholarship Foundation
  • Health and Human Services, Department of
  • Homeland Security, Department of
  • Housing and Urban Development, Department of
  • Interagency Council on the Homelessness
  • Inter-American Foundation
  • Interior, Department of the
  • International Boundary and Water Commission, United States Section
  • Justice, Department of
  • John F. Kennedy Center for the Performing Arts
  • Labor, Department of
  • Madison, James, Memorial Fellowship Foundation
  • Merit Systems Protection Board
  • Morris K. Udall Scholarship and Excellence in National Environment Policy Foundation
  • National Aeronautics and Space Administration
  • National Archives and Records Administration
  • National Credit Union Administration (not individual credit unions)
  • National Council on the Handicapped
  • National Endowment for the Arts
  • National Endowment for the Humanities
  • National Guard Activities (only through U.S. Property and Fiscal Officers)
  • National Labor Relations Board
  • National Science Foundation
  • National Transportation Safety Board
  • Navy, Department of
  • Nuclear Regulatory Commission
  • Nuclear Waste Technical Review Board
  • Occupational Safety and Health Review Commission
  • Office of Personnel Management
  • Office of Special Counsel
  • Peace Corps
  • Pension Benefit Guaranty Corporation
  • Postal Regulatory Commission
  • Presidio Trust, the
  • Railroad Retirement Board
  • St. Elizabeths Hospital
  • Securities and Exchange Commission
  • Selective Service System
  • Small Business Administration
  • Smithsonian Institution
  • Social Security Administration
  • State, Department of
  • Tennessee Valley Authority
  • Trade and Development Agency
  • Transportation, Department of
  • Transportation Security Administration
  • Treasury, Department of
  • U.S. Arms Control and Disarmament Agency
  • U.S. Secret Service
  • U.S. International Trade Commission
  • U.S. Navy Medical Research Unit
  • U.S. Postal Service
  • Veterans Affairs, Department of

Other Eligible Users

  • Administrative Office of the U.S. Courts
  • American Printing House for the Blind
  • American National Red Cross
  • American Samoa, Government of
  • Architect of the Capitol
  • Army/Air Force Exchange Service
  • Chemical Safety and Hazard Investigation Board
  • Civil Air Patrol
  • Coast Guard Auxiliary (through the U.S. Coast Guard)
  • CoBank, ACB
  • Committee for Purchase from People Who are Blind or Severely Disabled
  • Contractors and subcontractors- cost reimbursement (as authorized by the applicable agency’s contracting official)
  • Contractors and subcontractors- fixed price (security equipment only when so authorized by the applicable agency’s contracting official)
  • Courts, District of Columbia
  • Courts, Federal (not court reporters)
  • Delaware River Basin Commission
  • Denali Commission
  • District of Columbia, Government of
  • District of Columbia, Public Schools
  • District of Columbia, Pretrial Services Agency/Public Defenders
  • Eisenhower Exchange Fellowship
  • Election Assistance Commission
  • Farm Credit Banks (AgriBank FCB, Farm Credit Bank ofTexas, U.S. AgBank FCB, and AgFirst FCB)
  • Federal Coordinator for the Alaska Natural Gas Transportation Project
  • Federal Deposit Insurance Corporation
  • Federal Financial Institutions Examination Council
  • Federal Home Loan Banks
  • Federal Reserve Board of Governors
  • Firefighters, Non-Federal (as authorized by the Forest Service, U.S. Department of Agriculture)
  • Gallaudet University
  • Government Printing Office
  • Guam, Government of
  • House of Representatives, U.S. Howard University (including hospital)
  • Japan-United States Friendship Commission
  • Land Grant Institutions (as cost-reimbursement contractors)
  • Legal Services Corporation (not its grantees)
  • Library of Congress
  • Marine Mammal Commission
  • Medicare Payment Advisory Commission
  • Metropolitan Washington Airport Authorities
  • Millennium Challenge Corporation
  • National Capital Planning Commission
  • National Gallery of Art
  • National Railroad Passenger Corporation (AMTRAK)
  • National Technical Institute for the Deaf
  • Navajo and Hopi Indian Relocation, Office of
  • Naval Exchange Service Command
  • Neighborhood Reinvestment Corporation
  • Non-appropriated fund activities (not for resale)
  • Northern Mariana Islands, Government of the Commonwealth of the
  • Overseas Private Investment Corporation
  • Public Interest Declassification Board
  • Regional Fishery Management Councils
  • Senate, U.S.
  • South Atlantic Fishery Management Council
  • John C. Stennis Center for Public Service
  • Susquehanna River Basin Commission
  • U.S. Arctic Research Commission
  • United States Access Board
  • U.S. China Economic Security Review Commission
  • U.S. Institute of Peace
  • U.S. Tax Court
  • Vietnam Education Foundation
  • Virgin Islands, government of (including Virgin Islands Port Authority)
  • Washington Metropolitan Area Transit Authority (METRO)

International Organizations and Others Determined Eligible under Section 607 of the Foreign Assistance Act

  • African Development Fund
  • American Red Cross
  • Asian Development Bank
  • Counterpart Foundation, Inc.
  • Customs Cooperation Council
  • European Space Research Organization
  • Food and Agriculture Organization of the United Nations
  • Great lakes Fishery Commission
  • Inter-American Defense Board
  • Inter-American Development Bank
  • Inter-American Institute of Agriculture Sciences
  • Inter-American Investment Corporation
  • Inter-American Statistical Institute
  • Inter-American Tropical Tuna Commission
  • Intergovernmental Maritime Consultative Organization
  • Intergovernmental Committee for European Migration
  • International Atomic Energy Agency
  • International Bank of Reconstruction and Development (WORLD BANK)
  • International Boundary Commission-United States and Canada
  • International Boundary and Water Commission-United States and Mexico
  • International Center for Settlement of Investment Disputes
  • International Civil Aviation Organization
  • International Coffee Organization
  • International Cotton Advisory Committee
  • International Development Association
  • International Fertilizer Development Center
  • International Finance Corporation
  • International Hydrographic Bureau
  • International Institute for Cotton
  • International Joint Commission-United States and Canada
  • International labor Organization
  • International Maritime Satellite Organization
  • International Monetary Fund
  • International Pacific Halibut Commission
  • International Pacific Salmon Fisheries Commission-Canada
  • International Secretariat for Volunteer Services
  • International Telecommunications Union
  • International Wheat Council
  • Iraqi Ministry of Housing and Construction
  • Lake Ontario Claims Tribunal
  • Multinational Force and Observers
  • Multinational Investment Guarantee Agency (MIGA)
  • North Atlantic Treaty Organization (NATO)
  • Organization of African Unity
  • Organization of American States
  • Organization for Economic Cooperation and Development
  • Pan American Health Organization
  • Radio Technical Commission for Aeronautics
  • South Pacific Commission
  • United International Bureau for the Protection of Intellectual Property
  • United Nations
  • United Nations Educational, Scientific, and Cultural Organization
  • Universal Postal Union
  • World Health Organization
  • World Intellectual Property Organization
  • World Meteorological Organization
  • World Tourism Organization
Who buys from GSA?

Who buys from GSA?

GSA Sources of Supply and Services & Eligible Activities

who-buys-GSADo you and your sales team know who your GSA customers are?

Acquiring a Schedule means that you are now a part of GSA’s “Sources of Supply and Services” – that’s a seal of approval for any procuring agency that your company has been vetted and your service/products have been found to be “Fair & Reasonable.”  So let’s start winning opportunities…but who can buy what you sell?

Eligible Activities

Eligible Activities (also used interchangeably as Eligible Ordering Activities) are defined as organizations that have been authorized by statute and/or regulation to use GSA’s Sources of Supply and Services pursuant to 40 U.S.C. 501 – 502.  Eligible Activities are broken down into discrete listings of subcategories and will define the organization’s limitations and accessibility to GSA’s MAS Schedule program.  Per GSA Order ADM 4800.2H, the existing Eligible Activities are:

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