3.5 Blanket Purchase Agreements, SF 44 & Imprest Funds

3.5 Blanket Purchase Agreements, SF 44 & Imprest Funds

Quick Summary: A BPA is a recurring-purchase arrangement, SF 44 is a purchasing form, and an imprest fund is a payment mechanism. Choosing one does not waive competition, authority, funding or documentation requirements.

1. Identify the Governing Rules First

The Revolutionary FAR Overhaul (RFO) deviation model, checked on 10 October 2026, reorganizes these procedures. Apply the version and class deviation governing the particular agency and acquisition; publication of the model does not itself establish that every agency has adopted it. Older materials cite FAR 13.303 for BPAs, 13.305 for imprest funds and 13.306 for SF 44. Use these as a historical crosswalk, rather than assuming they are the operative citations under an adopted RFO deviation.

The baseline definitions are $15,000 MPT and $350,000 SAT. They are not universal: construction subject to wage-rate requirements has a $2,000 MPT, services subject to Service Contract Labor Standards have a $2,500 MPT, and specified emergency/contingency or other provisions can alter thresholds. Determine the applicable category before using a number.

2. What a BPA Does—and When an Obligation Arises

A simplified-procedure blanket purchase agreement fills anticipated repetitive needs by establishing a charge account with qualified sources. It can be established with several suppliers to support maximum practicable competition, or with one firm from which numerous individual purchases at or below the SAT are likely.

Establishing the arrangement is not an obligation to buy a guaranteed quantity. The current model states that the Government is obligated only to the extent of authorized purchases actually made under the BPA. Do not confuse it with a funded order or with an indefinite-delivery contract that contains a minimum guarantee. Confirm purchasing authority and available funding for the actual order; vendor delivery is not the event that first authorizes a commitment.

The BPA must specify the general supplies or services, period, any stipulated aggregate amount, the Government’s obligation limitation, individual-purchase dollar limit, people authorized to order, required delivery documentation, invoice instructions and applicable clauses. Periodic billing can simplify administration, but does not authorize purchases by unlisted personnel or cure an order that exceeds delegated authority.

Commercial and Noncommercial Ceilings Differ

Under current RFO 12.201-1(e)(3)(iv)(C), the individual commercial BPA purchase limit cannot exceed the simplified-procedure threshold: ordinarily $9 million, or $15 million for the qualifying acquisitions and agency-head determination in 12.001(c). This is a procedural ceiling, not a guarantee that every BPA authorizes an order that large. The BPA’s stated limit and the purchaser’s delegated limit still apply.

For noncommercial acquisitions, current RFO 13.201 says an individual BPA purchase may not exceed the applicable SAT—ordinarily $350,000. The commercial $9 million authority is not a general noncommercial BPA allowance. Never split an aggregate requirement merely to fit under a threshold.

Example: A noncommercial BPA specifies a $100,000 individual-purchase limit, and the ordering official is authorized up to $50,000. A $60,000 requirement is below the baseline SAT and below the BPA’s ceiling, but exceeds that official’s authority. It must go to someone with the necessary authority; making two $30,000 purchases does not cure the authority problem or justify improper splitting.

Competition and Continuing Review

The existence of a BPA does not justify soliciting only one source or avoiding small-business set-asides. Current RFO 12.102 and 12.103 apply to each order. For a purchase above the MPT, if existing BPAs provide insufficient maximum practicable competition, solicit other sources and, where practical, establish additional BPAs for recurring needs.

Micro-purchases are governed by 12.402: distribute them equitably among qualified suppliers to the extent practicable; competitive quotations are not required if the authorized buyer considers the price reasonable. If quotations are solicited and the lowest quote is not selected, document the suppliers solicited and a brief explanation. Do not turn this into an unconditional rotation rule for every BPA order or assume every procurement must select the lowest price.

Review BPAs at least annually under 12.201-1(e)(3)(v) to ensure authorized procedures are followed. Stay aware of changes in market conditions and sources of supply that warrant modification or new agreements. A Multiple Award Schedule BPA is governed by the applicable schedule ordering framework in Part 8; check that framework rather than applying every simplified-procedure BPA limit to it.

3. SF 44: All Conditions Must Be Met

The SF 44, Purchase Order–Invoice–Voucher, is a pocket-size multipurpose form for on-the-spot purchases of supplies and nonpersonal services while away from the purchasing office or at isolated activities. Under current RFO 12.403(b), use is limited and must be advantageous to the Government. All four conditions apply:

1. The agency authorizes SF 44 use. Possessing the form is not purchasing authority.
2. The amount is at or below the applicable MPT, or within a higher threshold the agency establishes for unusual and compelling urgency or contingency-operation support.
3. The supplies or services are immediately available, with one delivery and one payment.
4. SF 44 is determined to be more economical and efficient than the Governmentwide commercial purchase card.

The model does not establish a universal $25,000 aviation-fuel exception. An asserted higher limit needs its actual agency authority and qualifying circumstances. A planned series of deliveries or payments also fails the stated SF 44 condition, even when the total is small.

Example: Assume the ordinary $15,000 MPT applies and the agency authorizes SF 44. A $12,000 immediately available supply purchase with one delivery and payment satisfies the monetary and timing conditions, but still requires the efficiency determination. A $16,000 purchase exceeds that stated limit; being remote does not automatically authorize a higher one. A $12,000 purchase scheduled for three deliveries fails the one-delivery condition.

Follow applicable agency controls for form custody, purchase records and payment evidence. SF 44 is not a justification for avoiding authorized-buyer limits or delaying documentation until a convenient date.

4. Imprest Funds and Third-Party Drafts

An imprest fund is an advance of cash maintained for authorized disbursements and replenished against documented expenditures. It is distinct from a BPA and from the SF 44 form. Current RFO 12.403(c) permits imprest funds and third-party drafts only if the agency receives Department of the Treasury authorization, and purchases comply with Part IV of the Treasury Financial Manual.

• An imprest fund transaction must not exceed $500, or another limit approved by the agency head.
• A third-party draft transaction must not exceed $2,500, unless authorized at a higher level in accordance with Treasury restrictions.

These are qualified limits. Do not claim that all agencies can operate a cash fund without Treasury authorization, that an emergency automatically raises the limit, or that the FAR model itself restricts every fund transaction to one exhaustive list of emergency settings. Treasury authorization and applicable fiscal/agency controls determine whether the method is available.

Example: If the agency has Treasury authorization but has no agency-head approval for a different imprest limit, a $600 cash transaction exceeds the $500 limit. Dividing it into two $300 cash transactions does not supply missing authority. The buyer should use an authorized method or obtain the required authorization through the proper process.

5. Check the Arrangement, Authority and Payment Separately

Before proceeding, identify the commercial/noncommercial framework, required sources and competition rules; check the BPA/order or form conditions; confirm the individual buyer’s authority and funding; and use an authorized payment method with supporting records. The purchase card and purchase orders are the primary micro-purchase methods under 12.403(a). SF 44, imprest funds and third-party drafts have their own conditions, rather than acting as interchangeable exceptions.

Primary sources: RFO Part 12, 12.001(c), 12.201-1(e)(3), 12.402 and 12.403; RFO Part 13, 13.201 and 13.401; RFO Part 2, MPT and SAT definitions; the applicable agency deviation and Treasury authorization for an actual transaction.