When an ordering office establishes a BPA against a GSA Schedule contract, do orders placed under the BPA meet Competition in Contracting Act (CICA) requirements for full and open competition?

In accordance with FAR 6.102(d)(3), use of the Multiple Award Schedules Program is considered a “competitive procedure” under the Competition in Contracting Act of 1984 (CICA) when the MAS ordering procedures are followed; i.e., the Ordering Procedures For Services And Products Not Requiring A Statement Of Work in FAR 8.404 and the Ordering Procedures For Services (Requiring A Statement of Work). Thus, when an MAS BPA is established as a result of compliance with MAS ordering procedures, any order placed against the BPA meets CICA requirements.