Understanding the FAR: A Beginner’s Guide to Government Contracting (Part 8)
Welcome back to our comprehensive series on the Federal Acquisition Regulation (FAR). In the previous parts, we’ve covered everything from the basics to acquisition planning. Today, we’ll delve into Part 8, which focuses on Required Sources of Supplies and Services. This section is essential for understanding how the government prioritizes certain sources for procurement to support various public policies and programs.
Part 8: Required Sources of Supplies and Services
Part 8 of the FAR outlines the policies and procedures for using mandatory sources of supply and service before turning to the open market. These sources include government inventories, mandatory federal supply schedules, nonprofit agencies employing people who are blind or have severe disabilities, and more. Understanding these requirements helps ensure compliance and supports important government programs.
Subpart 8.1 – Excess Personal Property
Policy: Agencies must use excess personal property as the first source of supply. This helps reduce costs and support sustainability by reusing government-owned property.
Procedures: Agencies must search the General Services Administration (GSA) Excess Personal Property System before purchasing new items. If suitable property is available, it must be used instead of purchasing new supplies.
Subpart 8.2 – Federal Supply Schedules
GSA Schedules: The GSA Federal Supply Schedules, also known as GSA Schedules or Multiple Award Schedules (MAS), provide a simplified process for obtaining commercial supplies and services at negotiated prices.
Ordering Procedures: Agencies must follow specific ordering procedures when using GSA Schedules, including:
- Reviewing available schedules and selecting suitable contractors
- Placing orders directly with schedule contractors
- Documenting the rationale for the selection
Subpart 8.3 – Acquisition of Helium
Policy: The government must acquire helium from the Bureau of Land Management (BLM) as mandated by the Helium Privatization Act.
Procedures: Agencies must follow the procedures established by BLM for the acquisition of helium.
Subpart 8.4 – Federal Supply Schedules Ordering Procedures
Ordering Procedures for Supplies and Services: This subpart provides detailed guidance on the procedures for placing orders under Federal Supply Schedules, including:
- Fair opportunity requirements for orders exceeding the micro-purchase threshold
- Competition requirements for orders exceeding the simplified acquisition threshold
- Documentation requirements for orders and modifications
Subpart 8.5 – Acquisition of Used or Reconditioned Material
Policy: Agencies must consider acquiring used or reconditioned material when it is more cost-effective and meets the government’s needs.
Procedures: This includes conducting market research to determine the availability and suitability of used or reconditioned material and ensuring that it meets performance requirements.
Subpart 8.6 – Acquisition from Federal Prison Industries, Inc.
UNICOR: Federal agencies are required to consider purchasing products from Federal Prison Industries (FPI), also known as UNICOR, before turning to commercial sources. UNICOR provides job training and employment to federal inmates.
Procedures: Agencies must review UNICOR’s product offerings and purchase from them if their products meet the agency’s needs in terms of quality, price, and delivery time.
Subpart 8.7 – Acquisition from Nonprofit Agencies Employing People Who Are Blind or Severely Disabled
AbilityOne Program: The AbilityOne Program mandates that federal agencies purchase certain supplies and services from nonprofit agencies employing people who are blind or have severe disabilities.
Procurement List: The AbilityOne Commission maintains a Procurement List of supplies and services that must be purchased from these nonprofit agencies.
Subpart 8.8 – Acquisition of Printing and Related Supplies
Government Printing Office (GPO): The GPO is the mandatory source for printing and related supplies for federal agencies. Agencies must use GPO for their printing needs unless specific exemptions apply.
Procedures: Agencies must follow GPO’s procedures for submitting printing orders and ensure compliance with relevant regulations.
Key Principles for Using Required Sources
To effectively navigate Part 8 of the FAR, here are some key principles and best practices:
- Prioritize Mandatory Sources: Always prioritize mandatory sources of supply and service before considering open market purchases. This ensures compliance and supports government programs.
- Conduct Thorough Market Research: Perform thorough market research to identify suitable sources from excess property, GSA Schedules, UNICOR, and AbilityOne Program before seeking commercial suppliers.
- Document Decisions: Maintain detailed documentation of your decision-making process, including the rationale for selecting mandatory sources and any exemptions or deviations.
- Understand Ordering Procedures: Familiarize yourself with the specific ordering procedures for each mandatory source to ensure compliance and streamline the procurement process.
Practical Application: Case Studies
Let’s explore some hypothetical scenarios to illustrate how these principles apply in real-world situations:
Scenario 1: Using Excess Personal Property
Your agency needs office furniture for a new project. Here’s how you ensure compliance with Part 8:
- Search Excess Property: Before purchasing new furniture, you search the GSA Excess Personal Property System and find suitable items available for reuse.
- Utilize Available Items: You acquire the excess furniture, reducing costs and supporting sustainability efforts. This also ensures compliance with the policy to use excess personal property as the first source of supply.
Scenario 2: Procuring through GSA Schedules
Your agency requires IT consulting services for a system upgrade. Here’s how you comply with Part 8:
- Review GSA Schedules: You review the GSA Federal Supply Schedules to identify potential contractors offering IT consulting services.
- Fair Opportunity: You follow the fair opportunity procedures for orders exceeding the micro-purchase threshold and select a contractor based on technical capability, past performance, and price.
- Document the Order: You document the rationale for your selection and place the order directly with the chosen schedule contractor.
Scenario 3: Acquiring from AbilityOne Program
Your agency needs janitorial services for a new facility. Here’s how you navigate the requirements of Part 8:
- Review Procurement List: You review the AbilityOne Procurement List to determine if janitorial services are available from nonprofit agencies employing people who are blind or severely disabled.
- Procure from AbilityOne: You find a suitable provider on the Procurement List and contract with them for the required services, ensuring compliance with the AbilityOne Program.
Best Practices for Using Required Sources
Here are some practical tips to help your business stay compliant with Part 8 of the FAR:
- Regular Training: Ensure that procurement personnel receive regular training on the use of mandatory sources and the specific procedures associated with each.
- Collaborate with Suppliers: Build strong relationships with suppliers from mandatory sources, such as GSA Schedule contractors, UNICOR, and AbilityOne providers. This can help streamline the procurement process and ensure timely delivery of goods and services.
- Stay Updated: Regularly review updates to the Procurement List, GSA Schedules, and other mandatory sources to stay informed about new offerings and changes in policies.
- Monitor Compliance: Implement internal controls to monitor compliance with Part 8 requirements and conduct periodic audits to ensure adherence to mandatory source policies.
Conclusion
Part 8 of the FAR emphasizes the importance of using required sources of supply and services to support government programs and achieve cost-effective procurement. By understanding and adhering to these requirements, your business can ensure compliance, support important initiatives, and optimize its procurement strategies.
In our next installment, we’ll delve into Part 9 of the FAR, which covers Contractor Qualifications. Stay tuned as we continue to break down the FAR into manageable, understandable sections to help you succeed in government contracting.
