Overview
FAR Part 51 prescribes the policies and procedures that allow Government contractors to access Federal supply sources and the Interagency Fleet Management System (IFMS). These authorizations are generally granted when it is in the Government’s best interest to leverage its buying power or logistics infrastructure to reduce costs or increase efficiency under specific contract types.
Key Rules
- Eligibility Limitations: Authorizations are primarily reserved for cost-reimbursement contracts. Other negotiated contracts may qualify if a substantial portion of the contractor's work is cost-reimbursable.
- AbilityOne Requirements: Contracting Officers (COs) must authorize contractors to use Government sources when purchasing items from the Committee for Purchase from People Who Are Blind or Severely Disabled, provided the items are available through GSA, DLA, or VA facilities.
- Written Findings: Before authorizing use, the CO must document a written finding (except for AbilityOne items) considering cost savings, suitability, administrative expenses, and delivery timelines.
- Ordering Procedures: Contractors must use standardized systems such as FEDSTRIP (Federal Standard Requisitioning and Issue Procedures) or MILSTRIP (Military Standard Requisitioning and Issue Procedures) and include a specific authorization statement on orders.
- Vehicle Usage: IFMS vehicles are strictly for official purposes under cost-reimbursement contracts. Contractors must maintain liability insurance and establish penalties for any employee misuse of Government vehicles.
- Title to Property: Generally, title to property acquired through Government sources vests according to the "Government Property" clause in the contract; however, specific thresholds apply to educational institutions (typically under $5,000).
Responsibilities
- Contracting Officer (CO):
- Determines if using Government sources is in the Government's interest.
- Obtains necessary Activity Address Codes (AACs) from GSA or DoD.
- Monitors contractor compliance and ensures supplies/services are properly accounted for.
- Remains responsible for any indebtedness to the Government not satisfied by the contractor.
- Inserts FAR clauses 52.251-1 and 52.251-2 in applicable solicitations and contracts.
- Contractor:
- Uses Government sources only for the performance of the specific authorized contract.
- Submits requests for IFMS vehicles to the GSA regional fleet manager.
- Maintains motor vehicle liability insurance for IFMS use.
- Assumes non-reimbursable liability for any unauthorized use of Government vehicles.
- Makes prompt payment upon receipt of billings from GSA, DoD, or VA.
- GSA/DoD/VA:
- Provide ordering instructions and assistance with requisition forms.
- Bill the contractor only after supplies have been shipped.
Practical Implications
- Cost Savings: By allowing contractors to buy "off" Government schedules or from stock, the Government reduces the total burdened cost of cost-reimbursement contracts by avoiding commercial markups and leveraging sovereign price protections.
- Administrative Oversight: COs must be diligent in tracking "Activity Address Codes." If a contract ends or is terminated, the CO must manually notify the supply source to delete the contractor's access to prevent unauthorized "trailing" purchases.
- Risk Management: For vehicle use, the requirement for a written statement from the contractor to assume the cost of any unauthorized use serves as a critical indemnity for the Government.
- Subcontractor Access: Prime contractors can extend these benefits to subcontractors, but the Prime remains the gatekeeper; authorizations for subs must be issued through and approved by the Prime contractor.