3.5 Blanket Purchase Agreements (BPAs) & Imprest Funds (FAR 13.303 & 13.305)

3.5 Blanket Purchase Agreements (BPAs) & Imprest Funds (FAR 13.303 & 13.305)

Federal contracting officers utilize specialized procurement instruments to simplify repetitive purchasing operations and handle localized cash transactions. FAR Subpart 13.3 governs these specialized simplified acquisition instruments, including Blanket Purchase Agreements (BPAs), Imprest Funds, and Standard Form 44 (SF 44) over-the-counter purchase orders.

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Blanket Purchase Agreements (BPAs) under FAR Part 13

A Blanket Purchase Agreement (BPA) established under FAR 13.303 is a simplified method of filling anticipated repetitive needs for supplies or services by establishing "charge accounts" with qualified commercial sources. BPAs eliminate the administrative burden of issuing individual purchase orders for every routine transaction.

Critical Legal Nature of FAR Part 13 BPAs:

• NOT A CONTRACT: Under FAR 13.303-1(a), a FAR Part 13 BPA is not a contract. The agreement does not bind the Government to place orders or obligate the vendor to accept them.
• NO OBLIGATION OF FUNDS: Establishing a BPA does not obligate government funds. Funds are obligated only when an individual call order is placed against the BPA.
• DISTINCTION: FAR Part 13 BPAs are established directly with commercial suppliers under simplified acquisition procedures. They are legally distinct from FAR Part 8 Schedule BPAs, which are placed against existing GSA Multiple Award Schedule (MAS) contracts.

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Mandatory Terms and Conditions in BPAs (FAR 13.303-3)

Every BPA established under FAR 13.303 must incorporate mandatory contractual terms and conditions:

1. Description of Agreement: Summary of supplies or services to be furnished (e.g., routine plumbing repair services, electrical components).
2. Extent of Obligation: Explicit statement that the Government is obligated only to the extent of authorized call orders actually placed against the BPA.
3. Pricing Structure: Specified fixed prices, published catalog prices minus pre-negotiated discounts, or commercial price lists.
4. Notice of Authorized Individuals: List of designated individuals authorized to place call orders by name, position, or organizational title, including their specific single-call dollar limitations.
5. Delivery Tickets: Requirement that all shipments include itemized delivery tickets showing vendor name, BPA number, call number, date, itemized list of supplies, and quantity.
6. Invoicing & Monthly Billing: Summary monthly billing invoices incorporating delivery tickets to streamline payment processing.

Single vs. Multiple BPAs

Contracting officers should establish multiple BPAs with competing local suppliers whenever practical to ensure maximum practicable competition when placing individual call orders. When multiple BPAs exist, calls must be rotated equitably among agreement holders or placed competitively based on lowest price.

Mandatory Annual Review Requirement (FAR 13.303-6)

The Contracting Officer who established the BPA must review the agreement at least annually to determine whether:

• Vendor pricing structures remain fair and reasonable;
• Pre-negotiated discount rates were honored during the prior year;
• Multiple agreement holders received equitable opportunity; and
• Continuation of the BPA is in the best interest of the Government.

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Imprest Funds and Third-Party Drafts (FAR 13.305)

An imprest fund is a cash fund of a fixed amount established by an advance of funds from the Treasury to a designated Cash Verification Officer to make immediate cash payments for small purchases (FAR 13.305).

Severe Department of the Treasury Policy Restrictions:

Due to serious inherent risks of theft, fraud, loss, and administrative overhead, Department of the Treasury policy strictly curtails the use of imprest funds across all federal agencies. Executive policy mandates that all federal payments be made by electronic funds transfer (EFT) or Governmentwide Commercial Purchase Card.

Permitted Exceptions for Imprest Funds:

Contracting officers may establish imprest funds only under extraordinary circumstances, including:

• Emergency operations or national security missions;
• Highly classified acquisitions where electronic records compromised security; or
• Remote overseas (OCONUS) locations where electronic payment mechanisms and banking infrastructure are unavailable.

Imprest funds are subject to unannounced physical cash audits and strict transaction limits (typically restricted to purchases at or below $500, except for emergencies).

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Standard Form 44 (SF 44) Purchase Order-Invoice-Voucher (FAR 13.306)

Standard Form 44 (SF 44) is a pocket-sized, multi-copy form designed for on-the-spot over-the-counter purchases of supplies or services while personnel are in the field. It acts simultaneously as a solicitation, purchase order, invoice, and payment voucher.

[SF 44 Mandatory Operational Conditions (FAR 13.306(a))]
├── 1. Aggregate amount is AT OR BELOW Micro-Purchase Threshold ($15,000 Baseline)
│      └── EXCEPTION: Up to $25,000 for aviation fuel/oil during Contingency Operations
├── 2. Supplies or services are IMMEDIATELY AVAILABLE over the counter
├── 3. ONE delivery and ONE payment will be made upon receipt
└── 4. Economy and efficiency dictate its use over GPC or electronic SAP methods

SF 44 forms are accounted for as serialized, controlled government items. Personnel issuing SF 44s must maintain physical custody and submit completed vouchers immediately upon returning from field operations.