GAO 

United States Government Accountability Office

Report to the Committee on Oversight 

and Government Reform, House of 

Representatives 

CONTRACT 

MANAGEMENT 

Agencies Are Not 

Maximizing 

Opportunities for 

Competition or 

Savings under Blanket 

Purchase Agreements 

despite Significant 

Increase in Usage 

September 2009 

GAO-09-792 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

September 2009

CONTRACT MANAGEMENT 

Agencies Are Not Maximizing Opportunities for 

Competition or Savings under Blanket Purchase 

Highlights of GAO-09-792, a report to the Agreements despite Significant Increase in Usage 

Committee on Oversight and Government 

Reform, House of Representatives 

The Federal Acquisition Regulation 

(FAR) allows agencies to establish 

blanket purchase agreements 

(BPA) under the General Services 

Administration’s (GSA) Schedules 

Program, where contracts are 

awarded to multiple vendors for 

commercial goods and services and 

made available for agency use. 

BPAs are agreements between 

agencies and vendors with terms in 

place for future use; funds are 

obligated when orders are placed. 

When establishing BPAs under 

schedule contracts, agencies must 

follow procedures regarding the 

number of vendors considered, 

request discounts, and conduct 

annual reviews in accordance with 

requirements. This report assesses 

selected agencies’ use of schedule 

BPAs and evaluates whether they 

considered more than one vendor 

when establishing BPAs and 

placing orders under them, took 

opportunities for savings, and 

conducted annual reviews. To 

conduct this work, GAO reviewed a 

sample of 336 schedule BPAs and 

352 fiscal year 2007 orders and met 

with officials. 

What GAO Recommends

GAO recommends that the Office 

of Federal Procurement Policy 

(OFPP) clarify when establishing a 

BPA using the limited source 

justifications of the FAR is 

appropriate; increase competition 

under BPAs; and provide guidance 

on annual reviews. GAO also 

recommends that GSA assist 

agencies with language for 

discount requests. OFPP and GSA 

concurred with the 

recommendations. 

In fiscal year 2008, civilian agencies obligated $3.2 billion under schedule 

BPAs—up 383 percent from fiscal year 2004. GAO estimates that DOD’s 

obligations ranged from $0.5 to $4.7 billion, placing total obligations in 2008 

between $3.7 and $7.9 billion. GAO was unable to determine more fully DOD’s 

obligations because DOD does not utilize fields in the federal procurement 

data system to distinguish schedule BPAs from other BPAs. DOD has begun to 

take actions to address this issue. Civilian agencies’ use of BPAs for services 

grew significantly faster—475 percent—than their overall services contracting 

between 2004 and 2008. Contracting officers use BPAs for flexibility and 

speed, noting, for example, advantages in disaster response preparation and 

when funding for a fiscal year is unknown. 

Of the BPAs GAO reviewed, 64 percent had been competed—meaning, for 

purposes of this report, that more than one vendor was considered—when 

established. For 12 percent of BPAs that had not been competed, contracting 

officers provided a variety of justifications, some of which appear inconsistent 

with sound procurement policy. The FAR is not clear about justification 

requirements for BPAs awarded with limited competition, including to one 

vendor. Also, the majority of BPAs had been awarded to a single vendor, 

which resulted in a lack of competition when placing orders because the FAR 

does not currently require competition of orders under single award BPAs. 

Multiple award BPAs—awarded to more than one vendor for the same 

requirement—provide an opportunity to benefit from further competition 

when placing orders, but many contracting officers placed orders directly 

with one vendor without further competition. Congress recently enhanced 

competition requirements for multiple award contracts, but the application of 

this requirement to schedule BPAs has not yet been established. Some of the 

BPAs GAO reviewed had lengthy durations, exceeding 5 years. 

GAO found no evidence that agencies sought discounts when 47 percent of 

the BPAs reviewed were established. In the other cases, some contracting 

officers explicitly requested, or even demanded, discounts, while others 

merely encouraged them. Agencies frequently received discounts when they 

requested them. For instance, the Justice Department was able to save $20 

million under a BPA where the contracting officer requested and received 

discounts. However, at times, such opportunities were missed when discounts 

were not requested, even when the estimated amount of the BPA was in the 

hundreds of millions of dollars. 

Contracting officials rarely conducted the required annual reviews. The 

reviews for only 19 of the 320 BPAs that required them addressed all of the 

FAR elements. By not conducting annual reviews, agencies miss opportunities 

for savings and can run the risk of violating competition requirements. One 

contracting officer was unaware that the underlying GSA schedule contract 

had expired, and orders continued to be placed under the BPA—a potential 

violation of the Competition in Contracting Act. 

View GAO-09-792 or key components.

For more information, contact John Hutton at 

(202) 512-4841 or huttonj@gao.gov. 
Page i GAO-09-792 

Contents 

Letter 1

Background 4 

Civilian Agencies’ Use of Schedule BPAs for Services Has 

Increased Significantly, but DOD Data Issues Preclude an 

Accurate Picture of Total Government Use 8 

Agencies Did Not Take Full Advantage of Opportunities for 

Competition 12 

Agencies Often Did Not Seek or Receive Discounts from Schedule 

Pricing 17 

Agencies Generally Did Not Comply with the Annual Review 

Requirement and Missed Opportunities for Savings 20 

Conclusions 23 

Recommendations for Executive Action 24 

Agency Comments and Our Evaluation 25 

Appendix I Scope and Methodology 27 

Appendix II Comments from the General Services Administration 36 

Appendix III Comments from the Department of Health and 

Human Services 37 

Appendix IV Comments from the Department of Homeland 

Security 39 

Appendix V Comments from the Social Security Administration 41 

Appendix VI GAO Contact and Staff Acknowledgments 43 

Tables 

Table 1: Procedures when Placing Orders under Schedule BPAs 7 

 Blanket Purchase Agreements 
Table 2: Number of Schedule BPAs Reviewed from Five Civilian 

Agencies 28 

Table 3: Number of Schedule BPAs Reviewed from Defense 

Agencies 30 

Figures 

Figure 1: Procedures and Discounts when Establishing Schedule 

BPAs 6 

Figure 2: Obligations for Orders under Schedule BPAs for Products 

and Services —Civilian Agencies, Fiscal Years 2004 to 

2008 (in Constant Fiscal Year 2008 Dollars) 9 

Figure 3: Order Competition under Single and Multiple Award 

BPAs 16 

Figure 4: Range of Discounts Received by Agency 19 

Abbreviations 

BPA Blanket Purchase Agreement 

CECOM Communications and Electronics Command 

CICA Competition in Contracting Act 

DFARS Defense Federal Acquisition Regulation Supplement 

DHS Department of Homeland Security 

DLA Defense Logistics Agency 

DOD Department of Defense 

EDA Electronic Document Access 

FAR Federal Acquisition Regulation 

FEMA Federal Emergency Management Agency 

FPDS-NG Federal Procurement Data System-Next Generation 

GSA General Service Administration 

NIH National Institutes of Health 

TACOM Tank-Automotive and Armaments Command 

TSA Transportation Security Administration 

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Page ii GAO-09-792 Blanket Purchase Agreements
Page 1 GAO-09-792 

 

United States Government Accountability Office

Washington, DC 20548 

 

September 9, 2009 

The Honorable Edolphus Towns 

Chairman 

The Honorable Darrell Issa 

Ranking Member 

Committee on Oversight and Government Reform 

House of Representatives 

Federal contracting officers can choose from a variety of contracting 

mechanisms when buying goods and services. For example, they can 

award new contracts, issue orders under existing contracts at their 

agency, or issue orders under other agencies’ contracts. The General 

Services Administration’s (GSA) Schedules program is an interagency 

contracting mechanism used by many federal agencies. Under this 

program, GSA awards contracts to multiple vendors for commercially 

available goods and services and federal agencies place orders under the 

contracts. Agencies may establish blanket purchase agreements (BPA) 

under GSA’s schedule contracts.1

 BPAs are intended to be a simplified 

method of fulfilling repetitive needs for supplies and services that also 

provide an opportunity to seek reduced pricing from vendors’ schedule 

prices. Agencies may award BPAs to one vendor (known as a single award 

BPA) or to more than one vendor (multiple award BPAs), and then issue 

individual orders to fulfill requirements for goods and services as they 

arise. 

BPAs are not contracts, but rather agreements between government 

agencies and vendors with terms and conditions, including prices, in place 

for future use. The Federal Acquisition Regulation (FAR) was amended in 

2004 to require agencies to follow certain procedures when establishing 

and ordering from schedule BPAs and to document annual reviews to 

determine: whether each BPA still represents the best value; whether the 

GSA schedule contract under which the schedule BPA was established is 

still in effect; and whether the agency has exceeded its initial estimated 

purchase amount under the BPA, indicating a potential for discounts when 

more orders are placed. 

1

Another type of BPA, known as a traditional BPA, does not rely on GSA schedule contract 

terms and conditions and is subject to different regulations than schedule BPAs. In the 

remainder of this report, we use the term “schedule BPAs” to refer to BPAs established 

under GSA schedule contracts. 

 Blanket Purchase Agreements 
 

You expressed interest in understanding more about federal agencies’ use 

of schedule BPAs. Accordingly, we assessed (1) the extent to which 

agencies use schedule BPAs, what they buy with them, and why agencies 

use them; (2) whether agencies are competing BPAs and the orders under 

them; (3) whether agencies are taking advantage of opportunities for 

savings by seeking discounts when using these BPAs; and (4) whether 

agencies are conducting the required annual reviews. 

To conduct our work for each objective, we used an electronic data 

collection instrument to review 336 schedule BPAs and the largest fiscal 

year 2007 order under each, the most recent available data at the time we 

began our work.2

 Our scope included five civilian agencies and three 

defense agency locations. We reviewed 263 BPAs from the following 

agencies: the departments of Agriculture, Health and Human Services, 

Homeland Security, and Justice and the Social Security Administration. 

These agencies represented roughly 80 percent of the civilian dollars 

obligated under schedule BPAs in fiscal year 2007, based on data provided 

by GSA from the Federal Procurement Data System-Next Generation 

(FPDS-NG), the government’s primary database for information on 

procurement actions.3

 Because the Department of Homeland Security 

(DHS) had obligated the largest dollar amount, we selected all 155 of the 

department’s BPAs under which orders were placed during fiscal year 

2007. Therefore, our findings reflect the full universe of DHS schedule 

BPAs used in fiscal year 2007. We selected a random sample of 30 

schedule BPAs from each of the other four civilian agencies; our findings 

for those agencies are projectable to those agencies. We were unable to 

review 12 of the BPAs in our sample because some agencies could not 

locate the files. 

Because the Department of Defense (DOD) does not use available codes in 

FPDS-NG to identify its schedule BPAs, our methodology for selecting the 

defense locations (discussed in app. I) was more complex. We reviewed a 

random sample of 29 BPAs used by the Marine Corps Systems Command, 

30 from the Naval Air Systems Command, Naval Air Warfare Center, and 

all 14 of the schedule BPAs the Air Force District of Washington used 

 

2

 We reviewed 352 orders because, in some cases, more than one agency or component had 

issued an order under the same BPA. 

3

 GSA does not maintain specific information on the schedule BPAs established by federal 

agencies. 

Page 2 GAO-09-792 Blanket Purchase Agreements
 

during fiscal year 2007. Our findings are projectable only to the DOD 

locations selected. 

To assess the extent to which agencies are using schedule BPAs, we 

analyzed data from FPDS-NG for fiscal years 2004 to 2008 for civilian 

agencies. For DOD, given the data limitation discussed above, we 

constructed an estimate of its fiscal year 2008 usage based on our analysis 

of 100 randomly-selected procurements that we identified as BPAs using 

DOD’s contract naming system. We identified, via DOD’s online contract 

retrieval system, those in our sample that were in fact schedule BPAs and 

applied this percentage to DOD’s total spending under BPAs in general. 

For each objective, we supplemented our file reviews with follow-up 

questions when documentation in the file was insufficient. When agency 

officials did not respond to our questions or did not provide 

documentation that supported their response, we report these responses 

as providing no evidence. We also spoke with over 60 contracting officials 

across the agencies in our review about their use of schedule BPAs. 

Moreover, we spoke with officials from GSA to discuss the agency’s role 

with respect to schedule BPAs and FAR requirements for competition, 

discounts, and annual reviews. We spoke with officials from the Office of 

Federal Procurement Policy about policies concerning schedule BPAs. 

A more detailed description of our scope and methodology is presented in 

appendix I. 

As we describe in our methodology, we performed extensive tests to 

assess the reliability of the automated information we used to select our 

collection of BPAs. For example, we confirmed that the information 

contained in the automated records reflected the information contained in 

the contract files. We based our estimate of DOD’s use of schedule BPAs 

on information we verified using automated images of the contract 

records. Accordingly, we believe that the data we used to support our 

findings are reliable for our intended purposes. 

We conducted this performance audit from June 2008 to August 2009 in 

accordance with generally accepted government auditing standards. Those 

standards require that we plan and perform the audit to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe the evidence 

obtained provides a reasonable basis for our findings and conclusions 

based on our audit objectives. 

Page 3 GAO-09-792 Blanket Purchase Agreements
 

The FAR states that a BPA is a simplified method of filling anticipated 

repetitive needs for supplies or services that functions as a “charge 

account,” with terms and conditions agreed upon when the BPA is 

established. A BPA is not a contract; therefore, the government is not 

obligated to purchase a minimum quantity or dollar amount and the 

contractor is not obligated to perform until it accepts an order under the 

BPA. BPAs do not obligate funds; funds are obligated when an order 

subsequently is placed.4

Background 

Agencies may establish BPAs under GSA’s Schedule program contracts. 

Subpart 8.4 of the FAR provides procedures for using GSA schedule 

contracts, including establishing and ordering from BPAs. Prior to the 

issuance of the FAR in 1984 as the governmentwide procurement 

regulation, “blanket purchase arrangements,” a vehicle similar to BPAs, 

were permitted to be established with schedule contractors, if not 

inconsistent with the terms of the schedule contract, as early as the 1950s. 

Schedule BPAs use the pre-established terms and conditions of the GSA 

contract (such as prices and delivery terms) as a starting point, but 

ordering agencies may add terms and conditions, such as discounted 

pricing, as long as they do not conflict with those of the GSA contract. 

Each schedule BPA must address the frequency with which orders will be 

placed; invoicing procedures; discounts; delivery locations; time and 

requirements, such as the amount or quantity the agency expects to 

purchase under the BPA and the work the vendor will perform. The 

potential volume of orders under a BPA, as indicated by the estimated 

amount or quantity, provides an opportunity to seek discounts from the 

GSA schedule contract prices. 

From the first issuance of the FAR until 1994, agencies establishing 

schedule BPAs were required to follow the simplified acquisition 

procedures of Part 13, which emphasized “adequate” or “maximum 

practicable competition” at the time orders were placed. From 1994 until 

1997, the FAR and subsequent GAO bid protest decisions indicated that 

the policies and procedures of Part 13 did not apply to schedule BPAs and 

that agencies were to follow the procedures of Subpart 8.4 for placing 

orders on schedule BPAs, but not for their establishment. 5 Beginning in 

 

4

 Throughout this report, when we discuss obligations under BPAs, we are referring to 

obligations using BPA orders. 

5

 The procedures of FAR Part 13 still apply to traditional BPAs. 

Page 4 GAO-09-792 Blanket Purchase Agreements
 

1997, the FAR applied the ordering procedures in Subpart 8.4 to the 

establishment of schedule BPAs, including such steps as considering 

information about the supply or service offered under schedule contracts 

or reviewing the catalogs of schedule contractors.It also encouraged 

agencies to seek discounts when establishing schedule BPAs. A 2004 

amendment to the FAR clarified the BPA ordering procedures under 

Subpart 8.4 and explicitly required agencies to seek discounts. 

The FAR currently requires federal agencies to seek price reductions from 

vendors’ schedule prices and to follow certain procedures when 

establishing schedule BPAs. Which procedures are to be followed depends 

on whether the BPA will be used to purchase a product or service 

performed for a fixed price or for a service performed at an hourly rate, 

and thus requiring a statement of work. Procedures for establishing 

schedule BPAs and seeking discounts are depicted in figure 1. 

Page 5 GAO-09-792 Blanket Purchase Agreements
 

Figure 1: Procedures and Discounts when Establishing Schedule BPAs 

Is the BPA to purchase 

a product or a service 

performed for a fixed 

price?

Award

BPA(s)

No statement of work required

Review price lists for more than three 

schedule contractors

BPA is for a service performed for

an hourly rate (statement of work

required)

Provide the request for quotation 

(including the statement of work and 

evaluation criteria) to more than three 

schedule contractors that offer services

that will meet the agency’s needs

Request 

discounts

Source: GAO analysis of FAR 8.4. 

Yes No

Agencies may award a schedule BPA to a single vendor or to multiple 

vendors to fulfill the same requirement. The decision is to be based on a 

strategy that is expected to maximize the effectiveness of the BPA(s). The 

FAR states that, in determining how many BPAs to establish, contracting 

officers are to consider: 

• the scope and complexity of the requirement(s); 

• the need to periodically compare multiple technical approaches or prices; 

• the administrative costs of BPAs; and 

• the technical qualifications of the schedule contractors. 

Page 6 GAO-09-792 Blanket Purchase Agreements
 

After the BPA is established, requirements vary for considering more than 

one vendor when placing orders, as shown in table 1. 

Table 1: Procedures when Placing Orders under Schedule BPAs 

Single award BPA Multiple award BPAs 

Requirement to 

consider other 

vendors 

None required for the 

duration of the BPA. 

No requirement to consider more than one 

vendor for orders under the micropurchase 

threshold ($3,000). 

Above the micropurchase threshold, forward 

the requirement, or statement of work and the 

evaluation criteria, to an appropriate number 

of BPA holders, as established in the 

agency’s ordering procedures. 

DOD-specific requirement: Each order 

exceeding $100,000 shall be placed on a 

“competitive basis.” 

Sources: GAO analysis of FAR and DOD FAR Supplement. 

DOD is required to adhere to more stringent competition requirements 

than are at present applicable to civilian agencies. Section 803 of the 

National Defense Authorization Act for Fiscal Year 2002 directed DOD to 

amend its regulations to require that any purchase of services exceeding 

$100,000 under a multiple award contract be made on a competitive basis, 

subject to limited exceptions.6

 DOD’s implementation of this provision 

extended the competition requirement to orders under multiple award 

BPAs.7

 Hence, for such orders exceeding $100,000, DOD contracting 

officers are required to either (1) notify as many schedule contractors as 

practicable of the purchase to reasonably ensure that offers would be 

received from at least three contractors and receive three offers (or 

determine in writing that no additional contractors could be identified that 

can fulfill the requirement) or (2) notify all contractors offering the 

required services under the applicable schedule and afford all responding 

contractors a fair opportunity to submit an offer and have that offer fairly 

considered. Congress recently took action to apply multiple award 

competition requirements that are similar to those in the 2002 statute to all 

 

6

 Pub. L. No. 107-107, § 803 (2001) (repealed by the Duncan Hunter National Defense 

Authorization Act for Fiscal Year 2009, Pub. L. No. 110-417, § 863(f) (2008)). 

7

 Defense Federal Acquisition Regulation Supplement (DFARS) 208.405-70. Current 

regulations also expand the application to the ordering of supplies. 

Page 7 GAO-09-792 Blanket Purchase Agreements
 

executive agencies. The implementing regulations have not yet been 

promulgated.8

We estimate that the federal government obligated between $3.7 billion 

and $7.9 billion by placing orders under schedule BPAs during fiscal year 

2008. Civilian agencies reported spending almost $3.2 billion under 

schedule BPAs, with the five civilian agencies in our review obligating 

almost $2.3 billion of this amount, or almost 72 percent of total civilian 

agency obligations. Although orders under schedule BPAs (for goods and 

services) comprised only about 2.3 percent of civilian agencies’ reported 

obligations during fiscal year 2008, usage of schedule BPAs by civilian 

agencies has grown substantially over time, by 382 percent from fiscal year 

2004 to 2008 ($659 million to $3.2 billion).9

We were unable to develop similar trend information for DOD due to the 

data’s being unavailable, but for fiscal year 2008, we estimate that DOD 

obligated between $0.5 billion and $4.7 billion under schedule BPAs.10

Unlike civilian agencies, DOD does not use the available fields in FPDS-NG 

to distinguish its schedule BPAs from its traditional BPAs and indefinite 

delivery contracts.11 Therefore we could not readily determine DOD’s 

overall usage of schedule BPAs or what DOD is buying under these BPAs. 

We attempted to use data from DOD’s own procurement database (the 

DD350 database) and information from defense agency officials to identify 

schedule BPAs, but found additional inaccuracies. For example, we 

identified possible schedule BPAs for several Army organizations with 

obligations totaling roughly $319.8 million in fiscal year 2007. However, 

after further review and consultation with Army officials, we found that 

only about 16 percent of this amount had actually been obligated under 

Civilian Agencies’ Use 

of Schedule BPAs for 

Services Has 

Increased 

Significantly, but DOD 

Data Issues Preclude 

an Accurate Picture of 

Total Government Use 

 

8

Pub. L. No. 110-417, § 863. The legislation required that the FAR be amended no later than 

October 14, 2009. This legislation applies to all orders exceeding the simplified acquisition 

threshold (generally $100,000) and to the purchase of property or services. 

9

 Trend data are in constant fiscal year 2008 dollars. 

10 Appendix I contains a detailed explanation of our methodology for arriving at this 

estimate. 

11 DOD began feeding its procurement data directly into FPDS-NG in fiscal year 2007, a few 

years after civilian agencies. When DOD shifted from its DD 350 database to FPDS-NG, it 

carried with it some different coding conventions. We have previously reported on other 

coding differences. See GAO, Defense Contracting: Improved Oversight and Controls 

Needed Over DOD’s Time-and-Materials Contracts, GAO-07-273 (Washington, D.C.: June 

29, 2007). 

Page 8 GAO-09-792 Blanket Purchase Agreements
 

schedule BPAs. A DOD acquisition official informed us that the 

department is taking actions to implement new reporting procedures in 

FPDS-NG. 

Significant Growth in Use 

of Schedule BPAs for 

Services 

Civilian agencies’ use of schedule BPAs to purchase services has increased 

vastly more than their overall growth in services contracting in recent 

years. From fiscal years 2004 to 2008, civilian agency schedule BPA 

obligations for services increased by 475 percent, compared to a slightly 

negative growth in their overall service contracting. In addition, civilian 

agency schedule BPA purchases of services increased far more than their 

purchases for goods during the same time period. Figure 2 illustrates the 

trend in civilian agency obligations under schedule BPAs for products and 

services. We could not portray a similar analysis for DOD because of the 

data issue discussed earlier. 

Figure 2: Obligations for Orders under Schedule BPAs for Products and Services —

Civilian Agencies, Fiscal Years 2004 to 2008 (in Constant Fiscal Year 2008 Dollars) 

Dollars (in millions)

Source: GAO analysis of FPDS-NG data.

Fiscal year

Services

Products

0

500

1,000

1,500

2,000

2,500

3,000

3,500

FY2004 FY2005 FY2006 FY2007 FY2008

Page 9 GAO-09-792 Blanket Purchase Agreements
 

The majority of schedule BPAs in our sample—74 percent of the 336 DOD 

and civilian agency BPAs we reviewed—were established to acquire 

services as opposed to goods. The most frequently cited broad categories 

of services in the BPAs we reviewed were management support services, 

other professional services, and program management/support services. 

The estimated purchase amounts when the BPAs were established ranged 

from $10,000 to $734 million, with the average estimated dollar amount 

just over $64 million. 

Specific examples of services acquired under the schedule BPAs in our 

review include: 

• a BPA established by DHS for a range of acquisition support services, 

including drafting performance work statements and quality assurance 

surveillance plans; 

• a BPA established by the Federal Emergency Management Agency 

(FEMA) to provide program management support for implementing the 

Pre-Disaster Mitigation Program; 

• several BPAs established by the Navy to obtain analytical support for 

budget formulation and execution and other activities; and 

• a BPA established by the Food Safety and Inspection Service to obtain 

court reporting services. 

When the agencies established the BPAs in our sample to acquire goods, 

the most frequently cited categories were for data processing software; 

software and system configuration; and printing, duplicating, and 

bookbinding. For example, the Social Security Administration established 

a BPA to buy color copiers, and the Navy established a BPA to obtain 

software. Other examples of goods purchased through schedule BPAs in 

our sample include: 

• special purpose boats purchased by the Coast Guard for various law 

enforcement related missions; 

• body armor purchased by the Air Force; 

• laboratory equipment and supplies purchased by the Department of Health 

and Human Services; and 

• fire engines purchased by the Forest Service. 

Agencies Used BPAs for 

Flexibility, Speed, and to 

Meet Small Business Goals 

In addition to saying they use schedule BPAs to fulfill recurring needs, 

many of the contracting officials we spoke with cited BPAs’ flexibility and 

the speed with which they can be used as reasons they chose to use them 

as opposed to other contract vehicles, such as indefinite delivery 

contracts. Several contracting officials noted that schedule BPAs do not 

Page 10 GAO-09-792 Blanket Purchase Agreements
 

require the government to commit to any minimum dollar obligation or 

amount, as would an indefinite delivery/indefinite quantity contract. For 

example, a contract specialist at DHS’s Immigration and Customs 

Enforcement explained that his office does not receive funding, and 

therefore cannot obligate funds, until the budget is passed; in recent years, 

this has occurred during the second quarter of the fiscal year. Using a 

schedule BPA allows his office to be ready whenever it receives funds. 

Also, a contracting officer at FEMA said that she can establish a schedule 

BPA and have it ready for use when the agency has to respond to natural 

disasters and to conduct recovery operations without having to guarantee 

a minimum amount. However, some contracting officials noted that the 

lack of a binding contract can be a potential negative, since a vendor can 

decline to accept an order. One contracting official at the Marine Corps 

said that he prefers to have multiple BPA holders to ensure that vendors 

are available to meet the demand for goods and services. 

Contracting officers also indicated that the speed with which they can 

both establish BPAs and place orders under them is an advantage. For 

example, a contracting officer at the Marine Corps noted that schedule 

BPAs do not take a long time to negotiate because the solicitation process 

is streamlined and contracting officers are not required to advertise the 

solicitation on FedBizOpps, the Web site where government business 

opportunities greater than $25,000 are posted. As a result, he said it usually 

takes him a month or less to establish a schedule BPA, whereas it 

frequently takes him 3 to 4 months to award an indefinite delivery 

contract. Some contracting officers also told us that the ability to place 

BPA orders without competition is an advantage in terms of time saved. 

For example, a contracting officer at the Centers for Disease Control 

noted that a schedule BPA that has a broad scope of work makes it 

unnecessary to conduct a time-consuming competition each time he wants 

to place an order. A contracting officer at the Food Safety and Inspection 

Service stated that she can place orders under a single award BPA without 

further competition in less time than would be needed to meet the 

competition requirements for ordering directly from a GSA schedule 

contract. 

Some agencies also use schedule BPAs to help meet their small business 

goals. A contracting officer at the Social Security Administration told us 

that he uses schedule BPAs in part because there are many companies on 

the GSA schedule that meet the requirements of the Small Business 

Page 11 GAO-09-792 Blanket Purchase Agreements
 

Administration’s 8(a) business development program.12 We also reviewed a 

number of schedule BPAs, established by the Air Force to provide a wide 

range of advisory and assistance services, that involved teams of vendors 

often led by small businesses serving as prime contractors. 

Agencies in our sample competed BPAs when establishing them—meaning 

that, for purposes of this report, contracting officers considered more than 

one vendor—64 percent of the time.13 For a small number of BPAs in our 

sample (12 percent) contracting officers documented their rationale for 

not competing. We found no evidence that the remainder, 24 percent of 

the BPAs in our sample, were competed. For instance, at the National 

Institutes of Health (NIH), we found no evidence that 18 of the BPAs 

included in our sample were competed when established. Competition is 

the cornerstone of the acquisition system, and the benefits of competition 

are well established. It saves the taxpayer money, improves contractor 

performance, curbs fraud, and promotes accountability for results. 

Agencies Did Not 

Take Full Advantage 

of Opportunities for 

Competition 

When orders are placed under GSA schedule contracts, the FAR allows 

contracting officers to limit the number of vendors they consider, which 

includes considering only one vendor. However, the FAR does not 

explicitly apply this provision to the establishment of BPAs. The FAR 

specifically lists some examples of circumstances in which limited 

competition may be justified, including instances when (1) the work is 

unique or specialized in nature and only one source is capable of 

responding; (2) the new work is a logical follow-on to a previous 

requirement; or (3) an urgent and compelling need exists.14 In assessing 

agencies’ rationale for awarding BPAs directly to vendors without 

competition, we found justifications for doing so that were based on each 

of these circumstances. For example: 

 

12 The 8(a) program is one of the federal government’s primary means for developing small 

businesses owned by socially and economically disadvantaged individuals. Firms approved 

as 8(a) participants can receive business development assistance from the Small Business 

Administration. 

13 As noted earlier, prior to the amendments to the FAR in 1997, agencies were not required 

to consider more than one vendor when establishing a BPA. Eight of the 336 BPAs we 

reviewed were established prior to these changes and consequently were not required to be 

competed when established. 

14FAR 8.405-6. 

Page 12 GAO-09-792 Blanket Purchase Agreements
 

• Agencies purchased software from vendors who were the sole authorized 

vendors holding a GSA schedule contract. 

• The Social Security Administration awarded a BPA for program 

management, technical management, and administrative support because 

it was a logical follow-on to previous work. 

• The Coast Guard awarded a BPA to bridge the gap between the expiration 

of one contract and the competitive award of the next contract. 

In addition, we found four instances in which schedule BPAs were issued 

directly to one vendor because the vendor was designated as a small 

business or as an Alaska Native Corporation-owned business.15

However, we also found examples of justifications for awarding BPAs 

directly to one vendor that are not specifically mentioned in the FAR, 

some of which may not conform with sound procurement policy. A Navy 

contracting officer stated that it was not necessary to compete a BPA for 

engineering and technical services because GSA had already determined 

the vendor’s schedule pricing to be fair and reasonable.16 In two instances 

at the Justice Department, the contracting officer in one case stated that 

the vendor had performed well on a previous BPA, and in the other, that 

the vendor provided a deep discount. 

We discussed the lack of clarity regarding the applicability of FAR 

provisions regarding limiting competition when establishing BPAs with 

officials from the Office of Federal Procurement Policy.17 They agreed that 

action is needed to clarify the relevant provisions of the FAR and noted 

that discussions are ongoing regarding implementation of the provisions of 

section 863 of the Duncan Hunter National Defense Authorization Act for 

 

15Alaska Native Corporation-owned businesses, by statute, can participate in the Small 

Business Administration’s 8(a) business development program. See GAO, Contract 

Management: Increased Use of Alaska Native Corporations’ Special 8(a) Provisions Calls 

for Tailored Oversight, GAO-06-399 (Washington, D.C.: Apr. 27, 2006). 

16The FAR cites GSA’s determination of fair and reasonable pricing in the context of not 

requiring a separate determination of fair and reasonable pricing, not as justification for 

not following the processes in the FAR for considering multiple vendors when establishing 

a BPA. See FAR 8.404(d). 

17 The Administrator of the Office of Federal Procurement Policy serves as chair of the 

Federal Acquisition Regulatory Council (FAR Council). The FAR Council—whose members 

include the DOD Director of Defense Procurement and Acquisition Policy, NASA’s 

Associate Administrator for Procurement, and the GSA Chief Acquisition Officer—oversees 

development and maintenance of the FAR. 

Page 13 GAO-09-792 Blanket Purchase Agreements
 

Fiscal Year 2009, regarding competition requirements under multiple 

award contracts.18

Frequent Use of Single 

Award BPAs Resulted in 

Lack of Competition of 

Orders 

The FAR allows a contracting officer to decide whether to award a BPA to 

a single vendor or to multiple vendors for the same requirement. In 

determining how many BPAs to establish, the contracting officer is to 

consider such factors as the scope and complexity of the requirement and 

the administrative costs of the BPA. Over half of the BPAs in our sample 

(60 percent or 200) were single-award BPAs, and of these, we found no 

evidence of competition when the BPA was established for 19 percent or 

37 of them.19 One of the single award BPAs, established in 2004, for which 

we found no evidence of competition had an estimated amount of nearly 

$60 million. 

Further, once a single award BPA is established, all orders may be issued 

directly with the vendor without additional competition. We found this to 

be the case for the vast majority of orders under the single award BPAs in 

our sample; only 10 percent had been competed. Indeed, a number of 

contracting officers we spoke with cited this feature of single award BPAs 

as an advantage. The dollar value of some of the non-competed orders was 

fairly significant; 45 of the orders not competed under single award BPAs 

were greater than $1 million. For instance, DHS issued one of these orders 

for $37.6 million for professional information analysis and intelligence 

support, and the Coast Guard issued a $13.1 million order for network 

integration, software, and system integration support services. 

Agencies established a number of single award BPAs of fairly long 

duration, resulting in an extended period of time under which orders could 

be placed without additional competition. The FAR currently suggests that 

schedule BPAs should not exceed five years in length, but permits BPAs of 

longer duration.20 We found 28 instances in which agencies established 

single award BPAs with durations of at least 6 years, with a few single 

award BPAs in place for longer than 10 years, and one for over 20 years. 

Furthermore, of these 28 instances, we found evidence that competition 

 

18 Pub. L. No. 110-417, § 863 (2008). 

19 Four of these single award BPAs were established prior to the 1997 amendments to the 

FAR and consequently were not required to be competed when established. 

20 FAR 8.405-3(c). 

Page 14 GAO-09-792 Blanket Purchase Agreements
 

occurred when establishing the BPAs in only ten cases and that 

competition occurred when placing orders in only four of the cases. 

Agencies Did Not Take 

Full Advantage of 

Opportunities for 

Competition under 

Multiple Award BPAs 

The FAR requires agencies to follow specific procedures to compete 

orders under multiple award BPAs that exceed the micropurchase 

threshold ($3,000). Specifically, agencies are required to forward 

requirements, or statements of work and evaluation criteria, to an 

“appropriate number” of BPA holders, with the determination of what 

constitutes an appropriate number left to the discretion of the contracting 

officer.21 Contracting officers competed 49 percent of the orders above the 

micropurchase threshold with more than one vendor under the multiple 

award BPAs we reviewed.22 For 32 percent of the orders, contracting 

officers placed the order directly with one vendor and did not compete it 

with other vendors, the appropriate number effectively being one. For 

example, the Department of Agriculture did not compete an order worth 

$1.2 million for fire engines. For the remaining 19 percent of these orders, 

we found no evidence that contracting officers competed the order with 

more than one vendor. We found no evidence, for example, to suggest that 

DHS competed a $2.1 million order under one of its multiple award BPAs 

for information technology. Figure 3 shows the percentage of schedule 

BPAs in our sample that were established with a single vendor or with 

multiple vendors and the dollar value of orders competed and not 

competed for each type. 

 

21 FAR 8.405-3(b)(2). 

22 Prior to the 2004 amendments, the FAR did not always require agencies to consider more 

than one vendor when ordering from a BPA. 

Page 15 GAO-09-792 Blanket Purchase Agreements
 

Figure 3: Order Competition under Single and Multiple Award BPAs 

61.3% 38.7%

Source: GAO analysis of data obtained from contract files. 

Number of 

single award

BPAs

Number of

multiple award

BPAs

$87,781,345

$27,182,493

(200) (126)

$367,439,397

$9,427,473

Dollar value of orders competed

Dollar value of orders not competed

Note: We were not able to determine the type, single or multiple award, for 10 of the BPAs in our 

sample. 

The defense supplement to the FAR contains additional competition 

requirements for DOD, specifically that DOD compete orders under 

schedule BPAs exceeding $100,000 or justify the award if an order is not 

competed.23 Of the 37 orders subject to this requirement included in our 

sample, DOD competed or properly justified as sole source 28 of them. For 

the remaining 9 orders, there was no evidence of competition. Recent 

legislation directs that acquisition regulations be amended to require 

executive agencies to place on a competitive basis any order exceeding 

$100,000 that is made under a multiple award contract, but the 

implementing regulations are still pending and the extent to which this 

requirement will apply to orders under schedule BPAs is not certain.24

 

23 DFARS 208.405-70. 

24 Duncan Hunter National Defense Authorization Act for Fiscal Year 2009, Pub. L. No. 110-

417, § 863 (2008). 

Page 16 GAO-09-792 Blanket Purchase Agreements
 

Agencies frequently did not seek discounts when establishing schedule 

BPAs and rarely tried to obtain better pricing when placing orders.25 We 

found no evidence that agencies requested a discount for 47 percent of the 

BPAs we reviewed, even though GSA notes that agencies’ ability to 

negotiate discounts from schedule prices by leveraging their buying power 

through larger volume purchasing is one of the advantages of using 

schedule BPAs. By not requesting discounts when establishing schedule 

BPAs, agencies are missing opportunities to save money. 

Agencies Often Did 

Not Seek or Receive 

Discounts from 

Schedule Pricing 

Agencies frequently received discounts from GSA schedule prices if they 

requested them when establishing BPAs. For the 179 BPAs in our sample 

for which agencies requested discounts, discounts were received for 75 

percent of them. For example, the Department of Justice requested and 

subsequently received an 18 percent discount from the vendor’s GSA 

schedule pricing for a BPA used to procure information technology 

services. This discount saved the government roughly $20 million from 

fiscal year 2006, when the BPA was established, through July 2009 when 

the last order was placed, based on obligation data in FPDS-NG. In 

another instance, two BPAs awarded to the same vendor highlight the 

importance of requesting discounts. A contracting officer requested a 

discount when establishing a Navy BPA for analytical support services, 

and the vendor provided a 5 percent discount from its GSA schedule 

prices. In contrast, when establishing a different BPA for similar services 

from the same vendor, the contracting officer did not seek or receive a 

discount. If he had done so and received the same 5 percent discount 

applied to orders placed during the life of the BPA, the Navy would have 

saved almost $87,000. In another instance, a contracting officer at the 

Marine Corps did not seek, and subsequently did not receive, a discount 

for a schedule BPA whose estimated value was $205 million. 

Some contracting officers did not appear to understand the current 

requirement to seek discounts. In some cases, their rationale for not 

seeking discounts was based upon the statement in the FAR that GSA has 

already determined prices in the underlying schedule contract to be “fair 

and reasonable.” However, this FAR statement addresses the fact that 

ordering activities are not required to conduct additional price analyses 

when ordering supplies and services not requiring a statement of work 

 

25 Since 1997, seeking discounts when establishing schedule BPAs has been encouraged 

under FAR subpart 8.4, and in a 2004 amendment to the FAR this was explicitly required. 

Prior to 1997, the FAR did not always encourage or require seeking price reductions when 

establishing a schedule BPA. 

Page 17 GAO-09-792 Blanket Purchase Agreements
 

under the GSA schedule contracts. It does not negate the requirement to 

seek discounts when establishing schedule BPAs, which is clearly stated in 

FAR Subpart 8.4. One contracting officer said that using competition when 

establishing the BPA is the more significant determining factor for pricing, 

and thus he did not focus specifically on requesting discounts. 

Contracting officers who did request a discount usually included such 

language in the solicitation when establishing the BPA. In some cases, the 

contracting officer even made the offer of a discount a condition for 

awarding the BPAs—in effect, demanding a discount. For example, the 

request for quotation for two Navy BPAs stated, “Quoted prices, inclusive 

of fees must be discounted below GSA schedule prices.” The Department 

of Agriculture included the following statement in the request for 

quotation for one BPA: “Provide a proposed discount off your normal GSA 

schedule rates for the entire BPA period of performance.” The Air Force 

stated the following: “the contractor is expected to offer their (sic) best 

prices at or below the schedule price list.” In other cases, the request for a 

discount was more tentative. For example, the solicitation for a FEMA 

BPA stated, “the Government requests that you consider offering a 

discount percentage beyond the GSA Schedule pricing...” In a few 

instances, the contracting officer requested discounts via email or during 

negotiations. For example, a DHS contracting officer requested discounts 

during negotiations to establish a schedule BPA to provide technical 

support services to the Office of Immigration Statistics. 

The discounts agencies received when establishing BPAs varied widely. 

Vendors sometimes offered a single, flat rate discount for all items offered 

under the BPA, but we found it was more common for vendors to offer a 

range of discounts, with some goods or services more heavily discounted 

than others. Vendors’ flat rate discounts usually fell between 1 and 10 

percent. For instance, the Air Force obtained a 10 percent discount when 

establishing an estimated $99 million BPA to obtain advisory and 

assistance services. Some discounts were larger. DHS, for example, 

received a 76 percent flat rate discount on a $22 million BPA established to 

purchase software and services. When vendors provided ranges of 

discounts, the minimum discount was most often between zero and 

10 percent, while maximum discounts were more dispersed, with a 

majority ranging up to 30 percent. Some BPAs included discounts that 

varied by volume, while others included discounts that varied according to 

the product or service offered. For example, under a Department of 

Agriculture schedule BPA for software and associated maintenance, the 

vendor provided discounts ranging from 5 percent on a single order up to 

$250,000 to 20 percent on a single order over $1 million. The Social 

Page 18 GAO-09-792 Blanket Purchase Agreements
 

Security Administration received discounts ranging from 15 percent off 

labor rates to 91 percent off software under one of its schedule BPAs used 

to purchase software, maintenance, consulting services, and training. 

Figure 4 demonstrates the wide range of discounts received by each of the 

agencies in our sample. 

Figure 4: Range of Discounts Received by Agency 

0

10

20

30

40

50

60

70

80

90

100

United States Department

of Agriculture

Department of Justice

Health and

Human Services

Social Security

Administration

Department of

Homeland Security 

Department

of Defense

Percent

Agency

Source: GAO analysis of data obtained from contract files. 

Maximum discount

Minimum discount

Average flat rate discount

Note: For DOD, data reflects contract files reviewed from the Marine Corps Systems Command; 

Naval Air Systems Command, Naval Air Warfare Center, and Air Force District of Washington. 

Discounts Rarely Sought 

and Received for Orders 

In addition to requesting a discount at the time the schedule BPA is 

established, agencies can request additional discounts when they issue 

orders, although the FAR does not require them to do so. The agencies in 

our review infrequently requested discounts when placing orders. Of the 

352 orders we reviewed, agencies clearly requested discounts for 51 of 

Page 19 GAO-09-792 Blanket Purchase Agreements
 

them. Contracting officers indicated that their rationale for not seeking 

additional discounts when placing orders was the fact that pricing was 

already established at the time the BPAs were awarded. As with discounts 

at the time a BPA is established, we found that agencies were more likely 

to receive discounts when they specifically requested them than 

did not. In some cases, agencies had negotiated discounts when 

establishing the schedule BPAs and were also able to obtain further 

discounts for orders. In the Department of Justice example noted ab

which the vendor provided an 18 percent discount for the BPA, the 

contracting officer received an additional 10 percent discount for a $6

million order, saving $630,000. A vendor also provided an additional 

45 percent discount for a $2.6 million order under a BPA for which the 

Social Security Administration had already received discounts when the 

BPA was established, resulting in a dollar savings of over $1 million. As an 

illustrative example of the potential for savings, had the contracting officer 

in another case we reviewed negotiated even a 2 percent discount for a 

BPA with an estimated amount of $205 million, it would have saved nearly

$4 mil

when they 

ove, in 

.3 

lion based on obligations under this BPA from its establishment in 

2005. 

res 

e 

ct; 

n 

out 

they place orders when the underlying GSA contract is no longer in effect. 

 

Contracting officers had not conducted the required annual reviews for 

the vast majority of the schedule BPAs we reviewed. The FAR requi

contracting activities that establish schedule BPAs to conduct and 

document annual reviews containing three specific determinations: (1) th

schedule contract, upon which the BPA was established, is still in effe

(2) the BPA still represents the best value to the government; and (3) 

quantities or amounts estimated when the BPA was established have bee

exceeded and additional price reductions can be obtained.26 Only ab

one-fourth of the 320 BPAs that required annual reviews contained 

evidence that the contracting officer had conducted some form of review, 

and only 19 addressed each of the required elements. We found that some 

contracting officers lacked familiarity with the annual review requirement.

By not conducting annual reviews, agencies are missing opportunities for 

savings and may also run the risk of violating competition requirements if 

Agencies Generally 

Did Not Comply wit

the Annual Review

Requirement and 

Missed Oppo

h 

rtunities 

for Savings 

26 FAR 8.405-3(d). 

Page 20 GAO-09-792 Blanket Purchase Agreements
 

Contracting officers conducted annual reviews that addressed all of the 

required FAR elements for only 19 of the 320 BPAs in our sample that 

required an annual review.27 A number of contracting officers stated that 

they were unfamiliar with the FAR’s specific annual review requirements 

for schedule BPAs. Contracting officers also cited heavy workloads and a 

lack of acquisition personnel as additional reasons for not conducting 

annual reviews. Some contracting officers said that they did not know the 

requirement existed at all. For example, when we asked if an annual 

review had been conducted, one contracting official at FEMA asked to 

which FAR requirements we were referring. 

Few Contracting Officers 

Conducted Complete 

Annual Reviews 

In 63 additional instances, agencies did not complete all of the required 

elements of the annual review. In some cases, these reviews occurred 

while the contracting officers were conducting other activities associated 

with the BPAs. One contracting officer at the Department of Agriculture 

conducted a best value assessment when exercising an option year and 

verified that the GSA schedule contract was still in effect but did not 

document whether the original estimated BPA amount had been 

exceeded.28 In a case from the Department of Justice, a contracting officer 

verified that the GSA schedule contract was still in effect when issuing 

modifications to the BPA, but did not address any of the other required 

elements of the annual review. In other cases, contracting officers cited 

parts of the FAR outside of Section 8.4 when conducting their annual 

reviews and in doing so often did not complete required elements. When 

conducting annual reviews following sections of the FAR other than Part 

8, contracting officers often did not verify that the underlying schedule 

contract was still in effect or check to see if obligations under the BPA had 

exceeded the estimated amount. Some also failed to conduct a best value 

assessment that would inform decisions about whether the BPA should be 

continued. In seven cases, contracting officers at the Department of 

Agriculture and the Coast Guard documented annual reviews using FAR 

Section 13.303, which covers traditional BPAs, but did not make sure that 

the GSA schedule contract was still valid and did not determine whether 

the estimated amounts of the BPAs had been exceeded. In four other 

cases, contracting officers cited FAR Part 17 when conducting an annual 

 

27 Sixteen of the BPAs in our sample had a period of performance of one year or less or had 

been in effect for less than a year and therefore would not have required an annual review. 

28 Although a document in the file indicated that this contracting officer exercised an 

option year, we note that BPAs do not have options. In essence, this action extended the 

agreement by one year. 

Page 21 GAO-09-792 Blanket Purchase Agreements
 

review, which includes requirements for the exercise of options. In 

another case, a contracting officer cited FAR Section 16.702, which covers 

basic agreements. 

We found only two contracting activities that regularly conducted some 

sort of annual review. Contracting officers at DHS’s Citizenship and 

Immigration Services conducted annual reviews for 10 of the agency’s 

schedule BPAs we reviewed, although not all contained each of the 

required elements. The head of the contracting office attributed the 

consistency to an extremely low staff turnover rate as well as a mandatory 

back-up system that ensures that staff members’ workloads are always 

covered. In addition, all but one of the BPA files we reviewed at NIH 

contained some form of annual review, although, again, not all elements 

were always covered. An official responsible for NIH’s BPA program told 

us that contracting officials generally conducted the annual reviews to 

identify and terminate BPAs that were not being used. 

Annual Reviews Present 

Opportunities for Savings 

The required annual reviews present contracting officers with an 

opportunity to assess whether the BPA still represents the best value and 

to identify additional opportunities for discounts by determining whether 

the quantities or amounts estimated when the BPA was established have 

been exceeded and whether additional price reductions can be obtained. 

In some of the instances in which contracting officers conducted annual 

reviews, they determined that the schedule BPAs still represented the best 

value to the government in a variety of ways. For example, an annual 

review for a Health and Human Service BPA noted that the BPA still filled 

an existing need and provided continuity of service. A contracting officer 

managing a Marine Corps BPA checked that prices were still reasonable, 

while other annual reviews assessed whether market conditions had 

changed since the BPA was established. A contracting officer at the Social 

Security Administration used an annual review to obtain discounts. While 

conducting the review, he determined that the original estimated amount 

had been exceeded and successfully obtained discounts from the vendor. 

Contracting officers also informed us of instances in which conducting 

annual reviews helped them to better manage schedule BPAs. One 

contracting officer stated that when conducting annual reviews, she has 

occasionally found that prices for the schedule BPA have escalated, which 

led her to cease using those BPAs. 

By not doing the annual reviews, contracting officers missed opportunities 

for additional savings. For some of the BPAs in our sample, the BPA 

amount originally estimated had been exceeded, but because annual 

Page 22 GAO-09-792 Blanket Purchase Agreements
 

reviews were not conducted, agencies missed opportunities to obtain 

discounts. For instance, orders under a BPA established by the Marine 

Corps exceeded the BPA’s estimated amount within the third year of a 10-

year period of performance. Had the contracting officer conducted an 

annual review, he may have been able to use the volume of purchases as 

leverage to negotiate better prices with the vendor. 

By Not Conducting Annual 

Reviews, Agencies Risk 

Violating Competition 

Rules 

As part of the annual review process, contracting officers are required to 

verify that the underlying GSA schedule contract—under which the BPA is 

established—is still in effect. BPAs established under the schedule 

contract using the procedures of Subpart 8.4 are considered to be issued 

using full and open competition.29 Thus, orders properly placed under a 

valid schedule contract, whether directly or via a BPA, meet the 

requirements for competition under the Competition in Contracting Act 

(CICA) of 1984.30 In the absence of a valid schedule contract, any order 

placed using a schedule BPA does not meet those competition 

requirements, unless the procedures used to obtain the order 

independently satisfy the CICA requirements.31 Accordingly, if the 

underlying schedule contract has expired, subsequent orders using the 

schedule BPA may not be valid. We found one instance in which CICA was 

potentially violated among the BPAs and orders we reviewed. The 

underlying schedule contract for a Defense Logistics Agency BPA, under 

which the Navy placed an order in our sample, had expired. Although the 

Navy considered more than one schedule vendor when placing the order, 

this situation still involves a potential CICA violation because the 

underlying schedule contract had expired by the time the order was placed 

and it is not clear that statutory requirements for full and open 

competition were otherwise met. 

Schedule BPAs can provide federal agencies with a flexible and 

streamlined contracting mechanism for meeting repetitive procurement 

needs. However, especially in light of the significant increase in 

obligations under schedule BPAs, these potential benefits must be 

Conclusions 

 

29 FAR 8.404(a); 41 U.S.C. § 259(b)(3). 

30 Pub. L. No. 98-369, Div. B, Title VII, 98 Stat. 1175. 

31 Canon USA, Inc., B-311254.2, June 10, 2008. In this bid protest, Canon USA objected to 

the Army’s cancellation of an order under its schedule BPA. We denied the protest because 

the GSA schedule contract upon which the BPA was established had expired and therefore 

the BPA was no longer valid. 

Page 23 GAO-09-792 Blanket Purchase Agreements
 

balanced with ensuring that this mechanism is used appropriately and 

serves the best interests of the government and the taxpayer. Based on the 

failure of contracting officers across the agencies in our review to leverage 

competition, seek better pricing through discounts, and monitor the use of 

schedule BPAs by conducting annual reviews, it is apparent that those 

interests are not being met in many cases. This is particularly true for 

procedural requirements when establishing and ordering under schedule 

BPAs that require the consideration of multiple vendors. The high use of 

single award BPAs, under which no further competition is required when 

placing orders of any amount, reduces the potential to harness the benefits 

of competition, including additional savings for the taxpayer. And the 

FAR’s lack of clarity about the circumstances under which agencies can 

limit the number of vendors considered when establishing schedule BPAs, 

including establishing them with only one vendor, can lead to situations, 

such as we found, where justifications appear inconsistent with sound 

procurement policy. Further, the fact that so many contracting officers are 

either unaware of the requirement for annual reviews or simply are not 

conducting them means that opportunities are being missed to ensure that 

competition requirements are met and to seek better pricing from vendors. 

Finally, while some contracting officers clearly sought discounts from 

schedule prices, sometimes leading to millions in savings, many others did 

not. 

We are making the following three recommendations to the Administrator 

of the Office of Federal Procurement Policy: 

To ensure that federal agencies take greater advantage of the 

opportunities that competition provides under schedule BPAs: 

Recommendations for 

Executive Action 

• take steps to amend the FAR to clarify when establishing a schedule BPA 

using the limited source justifications of the FAR, including when to only 

one vendor, is or is not appropriate; and 

• consider including in the pending proposed FAR rule that implements the 

provisions of section 863 of the National Defense Authorization Act of 

2009 an amendment to FAR 8.4 specifying that the requirement to place on 

a competitive basis any order above the simplified acquisition threshold 

(generally $100,000) under multiple award contracts also applies to orders 

under single and multiple award BPAs. 

To improve compliance with the FAR requirement to conduct annual 

reviews of schedule BPAs, increasing opportunities for additional savings 

and avoiding violations of competition rules, take steps to require federal 

Page 24 GAO-09-792 Blanket Purchase Agreements
 

agencies to put procedures in place to ensure that annual reviews are 

conducted. 

Further, to assist federal agencies in requesting and obtaining discounts 

when establishing schedule BPAs, we recommend that the GSA 

Administrator include in the guidance on GSA’s Web site specific language 

which agencies can use in their requests for quotation to clearly request 

discounted pricing when establishing schedule BPAs. 

We requested comments on a draft of this report from the Office of 

Federal Procurement Policy; the departments of Agriculture, Defense, 

Health and Human Services, Homeland Security, and Justice; GSA; and the 

Social Security Administration. In oral comments, the Office of Federal 

Procurement Policy concurred with our recommendations. In written 

comments, included in appendix II, GSA concurred with our 

recommendation, noting that it will include in the guidance on its Web site 

specific language that agencies can use in their requests for quotation to 

clearly request discounted pricing when establishing schedule BPAs. The 

departments of Health and Human Services and Homeland Security 

generally agreed with our report and provided written comments, included 

in appendixes III and IV, respectively. The Department of Health and 

Human Services stated that it plans to take steps to reinforce compliance 

with BPA requirements. Health and Human Services also commented that 

while we found no evidence of competition for NIH’s BPAs included in our 

sample, NIH’s policy is to ensure that prices are competitive before 

awarding BPAs. Nonetheless, our review of the contract files for the 18 

BPAs selected showed no evidence of competition. The Department of 

Homeland Security discussed several actions it plans to take to improve 

management and use of BPAs. 

Agency Comments 

and Our Evaluation 

The Social Security Administration provided written comments, contained 

in appendix V, and provided new information regarding an example we 

had identified as a potential CICA violation that was discussed in our draft 

report. An annual review had not been conducted for the BPA, and the 

underlying GSA schedule contract had been canceled one year into a 7-

year period of performance. The agency had continued to place orders, 

totaling $3.4 million, under this BPA. In its comments, the Social Security 

Administration stated that there was no CICA violation because of changes 

made to the vendor’s underlying schedule contract. Several of the vendor’s 

schedule contracts had been consolidated into one single schedule 

contract, which was assigned a new contract number by GSA. The agency 

Page 25 GAO-09-792 Blanket Purchase Agreements
 

stated that the contracting officer had failed to reference the correct 

schedule contract number when placing orders under the BPA, but that 

this action did not violate CICA because the BPA was competed. We 

independently verified this new information, which was not contained in 

the BPA file, and therefore removed the example from our report. The 

Administration further noted that it has issued a reminder to its 

contracting officers to review BPAs annually to ensure, in part, that the 

underlying GSA schedule contracts are still in effect. 

In oral comments, the Department of Agriculture generally agreed with 

our report and did not provide additional comments. The departments of 

Defense and Justice did not provide comments. 

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution of it until 30 days from 

the date of this report. We will then send copies of this report to interested 

congressional committees; the Secretaries of Agriculture, Defense, Health 

and Human Services, and Homeland Security; the Attorney General; the 

Administrators of the General Services Administration and the Office of 

Federal Procurement Policy; and the Commissioner of the Social Security 

Administration. The report also is available at no charge on the GAO Web 

site at http://www.gao.gov. If you or your staff have any questions about 

this report, please contact me at (202) 512-4841 or huttonj@gao.gov. 

Contact points for our offices of Congressional Relations and Public 

Affairs may be found on the last page of this report. GAO staff who made 

John P. Hutton 

major contributions to this report are listed in appendix VI. 

Director 

Acquisition and Sourcing Management 

Page 26 GAO-09-792 Blanket Purchase Agreements
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

The overall focus of this review was agencies’ use of blanket purchase 

agreements (BPA) established under the General Administration Service’s 

(GSA) schedules program. Our objectives were to determine: (1) the 

extent to which agencies use schedule BPAs, what they buy with them, 

and why agencies use them; (2) whether agencies are competing BPAs and 

the orders under them; (3) whether agencies are taking advantage of 

opportunities for savings by seeking discounts when using these BPAs; 

and (4) whether agencies are conducting the required annual reviews. 

To conduct our work for each objective, we used an electronic data 

collection instrument to review 336 schedule BPAs and the largest 

associated order under each during fiscal year 2007, the most recent data 

available at the time we began our work. Our scope included five civilian 

agencies and three defense agency locations. We reviewed 263 BPAs from 

the following civilian agencies: the Departments of Agriculture, Health and 

Human Services, Homeland Security (DHS), and Justice and the Social 

Security Administration; and 73 BPAs from the following Department of 

Defense (DOD) components: Air Force, Marine Corps, and Navy. 

The five civilian agencies in our review represented roughly 80 percent of 

civilian agency obligations using orders under schedule BPAs during fiscal 

year 2007, based on data provided by GSA from the Federal Procurement 

Data System–Next Generation (FPDS-NG) on the dollar value of orders at 

the time the orders were placed. We selected a random sample of 30 

schedule BPAs per agency from the Departments of Agriculture,Health 

and Human Services, Justice, and the Social Security Administration, 

taken from the universe of all BPAs that the agencies ordered under 

during fiscal year 2007. Our findings for those agencies are projectable to 

those agencies. Because DHS had obligated the largest dollar amount to 

orders under schedule BPAs, we selected all 155 BPAs under which orders 

were placed during fiscal year 2007.1

 Our findings reflect the full universe 

of DHS’s schedule BPAs used in fiscal year 2007. 

In some instances, agency officials could not locate or provide the files 

associated with a given BPA. For example, Department of Agriculture 

officials could not locate the file for one of the BPAs in our sample, so we 

reviewed only 29 of Agriculture’s schedule BPAs. Likewise, because DHS 

 

1

 We excluded BPAs established or orders placed by the Transportation Security 

Administration (TSA) because TSA was not subject to the Federal Acquisition Regulation 

during fiscal year 2007. 

Page 27 GAO-09-792 Blanket Purchase Agreements 
Appendix I: Scope and Methodology 

officials could not locate and provide files for 11 of the BPAs, we reviewed 

144 BPA files. Table 2 shows the number of BPAs selected and reviewed at 

each civilian agency. 

Table 2: Number of Schedule BPAs Reviewed from Five Civilian Agencies 

Civilian agencies/components Number of BPAs selected/reviewed

Department of Agriculture 30/29

Department of Health and Human Services 30/30

Department of Justice 30/30

Social Security Administration 30/30

Department of Homeland Security 155/144

Total BPAs selected/reviewed 275/263

Source: GAO. 

We attempted to identify the agencies at DOD that represented roughly 

80 percent of DOD obligations to orders under schedule BPAs during fiscal 

year 2007, based on the dollar value of orders at the time the orders were 

placed, but were unable to do so because DOD was not using the fields in 

FPDS-NG that distinguish between BPAs and indefinite-delivery/indefinitequantity contracts. We attempted to use the DD350 data (DOD’s former 

procurement database) to identify DOD obligations to orders under 

possible schedule BPAs during fiscal year 2007 but found inconsistencies 

in the coding. Based on FPDS-NG data on all DOD BPAs—schedule and 

traditional—the Army, Defense Logistics Agency, Marine Corps, and Navy 

represented about 80 percent of defense obligations under all BPAs, based 

on the dollar value of orders at the time the orders were placed. Because 

of DOD’s size and geographic dispersion, we selected the contracting 

activity/location with the most dollars obligated to orders under possible 

schedule BPAs in fiscal year 2007 within the selected services and 

agencies, based on the preliminary data. We then selected a random 

sample of possible schedule BPAs from the selected contracting 

activities/locations. Our findings are projectable only to the DOD locations 

selected. 

We sought to determine whether the DOD BPAs in our sample were 

schedule BPAs by reviewing the documentation available in DOD’s 

Electronic Document Access System (EDA).2

 For the Marine Corps, all of 

 

2

 EDA is an online document access system designed to provide acquisition related 

information for use by all of the Department of Defense. 

Page 28 GAO-09-792 Blanket Purchase Agreements
Appendix I: Scope and Methodology 

the BPAs we selected were schedule BPAs. For the Navy contracting 

activity we had selected, only one of the original 30 BPAs we selected was 

not a schedule BPA (and therefore out of the scope of this review). We 

selected another BPA as a replacement. For the Defense Logistics Agency 

(DLA), the location that had the greatest obligations under BPAs was the 

Defense Supply Center-Philadelphia, Systems & Procedures Division. 

Because none of that location’s BPAs were listed in EDA, we asked 

officials at the Systems & Procedures Division to tell us whether the 30 

BPAs in our sample were schedule BPAs; they stated that none of them 

were schedule BPAs. We then contacted officials at another DLA location, 

the Defense Supply Center, Pacific Region, who stated that none of their 

BPAs were schedule BPAs. As a result, DLA dropped from our sample and 

we replaced it with the Air Force. 

We provided the Air Force contracting activity (the Air Force District of 

Washington) with a list of 25 possible schedule BPAs–the total number 

that had orders placed under them during fiscal year 2007–and asked 

officials to identify which ones were in fact schedule BPAs. An official at 

the Air Force District of Washington indicated that all 25 were schedule 

BPAs; however, when we reviewed the BPA files, we discovered that 6 of 

them were not schedule BPAs and dropped them from our sample. In 

addition, the Air Force contracting activity could not locate one BPA file, 

and the 754th Electronic Systems Group, Maxwell Air Force Base-Gunter 

Annex failed to provide information for four of the BPAs under which the 

Air Force District of Washington placed orders. 

With regard to the Army, based on FPDS-NG data, we identified the Army’s 

Communications and Electronics Command (CECOM) in Ft. Monmouth, 

New Jersey, as having the greatest amount obligated to orders under 

schedule BPAs. By reviewing the BPAs available in EDA, we discovered 

that only 2 of the 17 BPAs identified were schedule BPAs. We next looked 

at the Army’s Tank-Automotive and Armaments Command (TACOM) in 

Warren, Michigan. Because many of the BPAs used by TACOM were not 

available in EDA, we asked TACOM officials to identify which of the BPAs 

were schedule BPAs. They identified only 7 out of 63 BPAs as schedule 

BPAs. We next looked to the Army Contracting Command in Kuwait; an 

Army contracting official told us that all 76 of their BPAs were not 

schedule BPAs. Finally, we contacted the Army’s Contracting Center of 

Excellence in Washington, D.C. to ask officials there to identify the 

schedule BPAs from a list of 50 candidates. An associate director from the 

Center of Excellence told us that the center was unable to identify the 

schedule BPAs. We did not replace the Army with another defense agency. 

Table 3 shows the number of reviewed at the selected defense agencies. 

Page 29 GAO-09-792 Blanket Purchase Agreements
Appendix I: Scope and Methodology 

Table 3: Number of Schedule BPAs Reviewed from Defense Agencies 

DOD agencies/components Number of BPAs reviewed

Air Force — Air Force District of Washington 14

U.S. Marine Corps — Systems Command 29a

U.S. Navy — Naval Air Systems Command 30

Total 73

Source: GAO. 

a

We initially selected 30 schedule BPAs used by the Marine Corps; we subsequently determined that 

one had also been included in our review of the Air Force’s BPAs. 

For all agencies, both civilian and defense, we selected the BPAs based on 

the agency and location where the orders were placed. For example, the 

Navy location selected for our review, the Naval Air Systems Command, 

had placed orders under four schedule BPAs established by the Naval 

Inventory Control Point – Mechanicsburg. We included these four BPAs in 

our sample for the Naval Air Systems Command. In another instance, the 

Naval Air Systems Command ordered under a schedule BPA established 

by the Defense Information Systems Agency; again, the BPA was included 

in our sample. 

We reviewed 352 orders under the BPAs in our sample. We selected the 

order placed during fiscal year 2007 that obligated the largest dollar value 

at the time of award. In some instances, more than one order was selected 

under a single BPA, resulting in a greater number of orders than BPAs 

selected. For example, at DHS, both Citizenship and Immigration Services 

and Immigration and Customs Enforcement placed orders under the same 

BPA; we selected the highest dollar value order placed under the BPA 

from each component for review. In addition, in some cases, where an 

agency could not provide the file for the BPA, the agency was able to 

provide the file for the order. 

We used an electronic data collection instrument and verified the 

information on-site to conduct our review of the BPA and order files and 

to facilitate our analysis. We supplemented our file reviews with follow-up 

questions when documentation in the file was not available, insufficient, 

or unclear. In some instances, we received additional documentation from 

agency officials, which we analyzed and incorporated in our final results 

when appropriate. When agency officials did not provide documentation 

that supported their response, we reported the response to our question as 

“not documented” or “no evidence.” In some cases, we interviewed the 

contracting officer or contract specialist to obtain clarification. 

Page 30 GAO-09-792 Blanket Purchase Agreements
Appendix I: Scope and Methodology 

To assess the extent to which agencies use schedule BPAs, what they buy 

with them, and why agencies use them, we used data from FPDS-NG, data 

from our file review, and information provided by contracting officials. 

More specifically, we analyzed data from FPDS-NG on civilian agency 

procurements for fiscal years 2004 to 2008 to determine the 5-year trend in 

BPA use among civilian agencies and to compare the use of schedule 

BPAs to obtain services with the overall growth in contracting for services. 

To do so, we converted the data into fiscal year 2008 constant dollars 

using the Bureau of Economic Analysis price index for services in the 

federal consumption expenditures category. To determine why agency 

officials chose to establish and use schedule BPAs rather than other 

contracting vehicles, we interviewed contracting officials across the 

agencies included in our review about their use of schedule BPAs. To 

determine what products and services agencies intended to purchase 

using the schedule BPAs in our sample, we analyzed data from our file 

review. 

To estimate DOD’s usage of schedule BPAs for fiscal year 2008, we used 

DOD’s contract coding system to identify the BPAs in FPDS-NG under 

which DOD agencies placed orders during fiscal year 2008. From that 

universe, we selected a random sample of BPAs. We used the EDA, DOD’s 

online contract retrieval system, to review the BPAs. In the event that a 

BPA was not available in EDA, we replaced it with the next BPA on our 

list until we had 100 BPAs. In the three instances in which the 

documentation in EDA was insufficient to make a determination as to 

whether the BPA was a schedule BPA, we contacted the agency for 

clarification. In two of these instances, the contacting officer did not 

respond, and we replaced the BPAs with the next on our list. Next, we 

obtained data from FPDS-NG on the amount obligated using orders under 

these BPAs during fiscal year 2008. We found that 25 of the BPAs in our 

sample of 100 were schedule BPAs; orders under the 25 schedule BPAs 

obligated $106,011,561 of the $143,711,789 obligated to orders under the 

100 BPAs in our sample. Based on this information, we estimate that 852 

of the 5,178 DOD BPAs in FPDS-NG are schedule BPAs, with the 95 

percent confidence interval between 589 and 1200 BPAs. We estimate their 

value as $3.3 billion, about 65 percent of the $5.1 billion value of all BPAs, 

with the 95 percent confidence interval between $0.5 and $4.7 billion. 

To determine whether agencies are competing BPAs and the orders under 

them and whether agencies are taking advantage of opportunities for 

savings by seeking discounts when using these BPAs, we analyzed the data 

we obtained during reviews of the BPA and order files concerning 

competition and discounts, following up when necessary with additional 

Page 31 GAO-09-792 Blanket Purchase Agreements
Appendix I: Scope and Methodology 

questions and interviews of contracting officials. We reviewed BPA files to 

determine whether the requirement was competed when the BPA was 

established and when an order was placed by determining whether more 

than one vendor had been contacted. We also identified the ordering 

procedures in the Federal Acquisition Regulation (FAR) and the Defense 

Federal Acquisition Regulation Supplement (DFARS) and the level of 

competition required under them. We discussed with contracting officials 

what factors were considered when deciding to establish single vs. 

multiple award BPAs. To determine whether contracting officials sought 

discounts and whether the contractor provided discounts either when the 

BPA was established or when orders were placed, we reviewed files for 

the BPA and the order. We then followed up with contracting officers or 

contract specialists as needed. 

To determine whether the agencies in our sample are conducting the 

required annual reviews, we examined the files for the schedule BPAs in 

our sample for documentary evidence of each element of the annual 

review as listed in FAR 8.405-3(d). Where there was no documentation of 

annual reviews in the contract file, we asked agency officials to provide us 

with the appropriate documentation. We conducted interviews with 

agency contracting officials, to determine how they interpreted the 

relevant FAR provision and clarify information in the BPA files. We 

reviewed the contract files to determine whether the GSA schedule 

contracts had expired. If there was no GSA schedule data in the BPA file 

or the file suggested that the schedule contract had expired, we searched 

the GSA website (GSA e-Library) to determine whether the GSA schedule 

contracts were still in effect. For those schedule contracts that were no 

longer listed on GSA e-Library, we contacted GSA to obtain 

documentation of either the date the schedule contract expired or the 

current expiration date. We reviewed the BPA files to determine if the 

contracting officer or contract specialist checked to see if estimated 

amounts had been exceeded. 

We visited or contacted the following offices for our review: 

Department of Agriculture: 

• Agricultural Research Service, Beltsville, Maryland 

• Food and Nutrition Service, Alexandria, Virginia 

• Food Safety and Inspection Service, Beltsville, Maryland 

• U.S. Forest Service 

• Arlington, Virginia 

Page 32 GAO-09-792 Blanket Purchase Agreements
Appendix I: Scope and Methodology 

• Atlanta, Georgia 

• Northwest Oregon Contracting Area, Sandy, Oregon 

• National Finance Center, New Orleans, Louisiana 

• Office of Procurement and Property Management 

• Washington, D.C. 

• Fort Collins, Colorado 

General Services Administration, Washington, D.C. 

Department of Health and Human Services: 

• Health Resources and Services Administration, Rockville, Maryland 

• National Institutes of Health, Rockville, Maryland 

• Office of the Assistant Secretary for Administration and Management, 

Washington, D.C. 

Department of Homeland Security: 

• Citizenship and Immigration Services, Williston, Vermont 

• Customs and Border Protection 

• Washington, D.C. 

• Indianapolis, Indiana 

• Federal Emergency Management Agency 

• Atlanta, Georgia 

• Chicago, Illinois 

• Austin, Texas 

• Mt. Weather, Virginia 

• New Orleans, Louisiana 

• Washington, D.C. 

• Immigration and Customs Enforcement 

• Dallas, Texas 

• Denver, Colorado 

• Grand Prairie, Texas 

• Philadelphia, Pennsylvania 

• Washington, D.C. 

• Office of Procurement Operations, Washington, D.C. 

• U.S. Coast Guard 

• Baltimore, Maryland 

• Washington, D.C. 

Page 33 GAO-09-792 Blanket Purchase Agreements
Appendix I: Scope and Methodology 

Department of Justice: 

• Bureau of Alcohol, Tobacco, Firearms and Explosives, Washington, D.C. 

• Federal Bureau of Prisons, Washington, D.C. 

• Drug Enforcement Administration, Arlington, Virginia 

• Justice Management Division, Washington, D.C. 

• Office of the Federal Detention Trustee, Arlington, Virginia 

Office of Federal Procurement Policy, Washington, D.C. 

Social Security Administration, Baltimore, Maryland 

Department of Defense: 

• Defense Procurement and Acquisition Policy, Arlington, Virginia 

• Department of the Air Force 

• Air Force District of Washington, Washington, D.C. 

• Department of the Army 

• Office of the Deputy Assistant Secretary of the Army, Arlington, 

Virginia 

• Army Contracting Agency, Contracting Center of Excellence, 

Alexandria, Virginia 

• Tank-Automotive and Armaments Command, Warren, Michigan 

• U.S. Marine Corps, Quantico, Virginia 

• Department of the Navy 

• Naval Air Warfare Center – Aircraft Division, Patuxent River, Maryland 

• Naval Inventory Control Point, Mechanicsburg, Pennsylvania 

• Space and Naval Warfare Systems Command Systems Center, San 

Diego, California 

• Defense Information Systems Agency, Defense Information Technology 

Contracting Organization, Scott Air Force Base, Illinois 

• Defense Logistics Agency 

• Defense Supply Center Philadelphia, Pacific Region, Pearl Harbor, 

Hawaii 

• Defense Supply Center Philadelphia, Philadelphia, Pennsylvania 

• Enterprise Support Base Contracting Office, Fort Belvoir, Virginia 

As we describe in our methodology, we performed extensive tests to 

assess the reliability of the automated information we used to select our 

collection of BPAs. For example, we confirmed that the information 

contained in the automated records reflected the information contained in 

Page 34 GAO-09-792 Blanket Purchase Agreements
Appendix I: Scope and Methodology 

the contract files. We based our estimate of DOD’s use of schedule BPAs 

on information we verified using automated images of the contract 

records. Accordingly, we believe that the data we used to support our 

findings are reliable for our intended purposes. 

We conducted this performance audit from June 2008 to August 2009, in 

accordance with generally accepted government auditing standards. Those 

standards require that we plan and perform the audit to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions 

based on our audit objectives. 

Page 35 GAO-09-792 Blanket Purchase Agreements
Appendix II: Comments from the General Appendix II: Comments from the General Services Administration 

Services Administration 

Page 36 GAO-09-792 Blanket Purchase Agreements 
Appendix III: Comments from the Department Appendix III: Comments from the of Health and Human Services 

Department of Health and Human Services 

Page 37 GAO-09-792 Blanket Purchase Agreements
Appendix III: Comments from the Department 

of Health and Human Services 

Page 38 GAO-09-792 Blanket Purchase Agreements
Appendix IV: Comments from the Department Appendix IV: Comments from the of Homeland Security 

Department of Homeland Security 

Page 39 GAO-09-792 Blanket Purchase Agreements 
Appendix IV: Comments from the Department 

of Homeland Security 

Page 40 GAO-09-792 Blanket Purchase Agreements
Appendix V: Comments from the Social Appendix V: Comments from the Social Security Administration 

Security Administration 

Page 41 GAO-09-792 Blanket Purchase Agreements 
Appendix V: Comments from the Social 

Security Administration 

Page 42 GAO-09-792 Blanket Purchase Agreements
Appendix VI: 

A

GAO Contact and Staff 

cknowledgments 

Page 43 GAO-09-792 

Appendix VI: GAO Contact and Staff 

Acknowledgments 

John P. Hutton, (202) 512-4841 or huttonj@gao.gov 

In addition to the contact named above, Michele Mackin, Assistant 

Director; Kathryn Edelman; Bridget Grimes; Paula J. Haurilesko; Art 

James, Jr.; Brandon Jones; Julia Kennon; Arthur Lord; Susan Neill; 

Kenneth Patton; Caitlin A. Tobin; and Alyssa Weir made key contributions 

to this report. 

 Blanket Purchase Agreements 

GAO Contact 

Acknowledgments 

(120741) 
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