Intermediate Track • Topic 26

GSA Delivery Orders under the SAT

Ordering from GSA schedules for purchases under the Simplified Acquisition Threshold. Understand when you need competition, how to conduct it, and what documentation you must keep.

Training

Ordering Against GSA Schedules

GSA Federal Supply Schedules are pre-competed contracts. But that doesn't mean you can skip the ordering process. Learn the streamlined ordering procedures under GSAM 538.71 — they're simpler than you think.

1 What Is a GSA Schedule Order?

GSA Federal Supply Schedules (also called Multiple Award Schedules or MAS) are pre-competed, pre-priced contracts between GSA and commercial vendors. When you order from a GSA schedule, you are not conducting a new procurement — you are placing an order against an existing contract.

The schedule contract already established that the prices are fair and reasonable at the contract level. Under the Revolutionary FAR Overhaul (RFO), FAR 8.4 now points directly to GSA's own ordering procedures at GSAM 538.71. The current Simplified Acquisition Threshold is $350,000.

The critical thing to understand: GSA schedules are a contract vehicle, not a procurement method. Ordering from a GSA schedule still requires you to follow the ordering procedures established by GSA at GSAM subpart 538.71.

RFO Change: Before the overhaul, the FAR itself contained detailed GSA ordering procedures at FAR 8.405-1 (supplies) and 8.405-2 (services). Under the RFO, FAR 8.4 was stripped down to a single section that directs you to follow GSA's ordering procedures at GSAM 538.71. The practical steps are similar, but the citation has moved.

2 When Can You Use a GSA Schedule?

A few conditions must be met before you can place a GSA schedule order:

The requirement must be a commercial product or service. If it's available on a GSA schedule, it's commercial. If it's not commercial, it won't be on a schedule.

You must confirm the vendor has a current, active schedule contract. Check GSA Advantage or GSA eLibrary. Schedules expire. Always verify the contract is still in force before you place the order.

What you're ordering must be on the contractor's schedule. If it's listed on their schedule contract, you're good. You can verify this on GSA Advantage or eLibrary.

Ordering from GSA schedules satisfies the competition requirement. You do not need a separate J&A or competitive action on the open market. The pre-competition at the schedule level is your competition.

Important: GSA schedules are not mandatory. They are one tool among many. If you can get a better deal through open market procedures, you can do that instead.

3 Orders at or Below the Micro-Purchase Threshold ($10,000)

Per GSAM 538.7103-1, for orders at or below the micro-purchase threshold (MPT), you can place the order directly with any schedule contractor that can meet the need. No additional competition is required beyond the competition already inherent in the schedule program.

You still need to verify that the contractor has an active schedule and the item or service is on their schedule. You should also try to distribute orders among FSS contractors when possible. Document the file: what you bought, who you bought it from, the schedule contract number, and the price.

This is the fastest path: Find it on GSA Advantage, confirm the schedule is active, place the order, and document it. Done.

4 Orders Above the MPT but at or Below the SAT ($10,001 – $350,000)

This is the core of GSA ordering. Per GSAM 538.7103-2, for orders in this range, you must seek competition among schedule holders. How you do it depends on whether the requirement is clearly defined.

If the product or service is clearly defined and available at a fixed price (538.7103-2(a)), you have four options — use any one:

  1. Survey at least three FSS contractors on GSA Advantage — look up the pricing, screenshot it, and document your selection. This is the simplest path for clearly defined, fixed-price items.
  2. Review FSS contract catalogs of at least three contractors
  3. Publish an RFQ on GSA eBuy
  4. Issue an RFQ directly to at least three FSS contractors

If the product or service is NOT clearly defined — it involves a statement of work/objectives, order-level materials, or is not available at a fixed price (538.7103-2(b)) — you must either:

  1. Publish an RFQ on GSA eBuy, or
  2. Issue an RFQ to at least three FSS contractors

In either case, evaluate the quotes, award to the contractor offering best value, and notify unsuccessful quoters.

Quotations are not offers. Per GSAM 538.7102-2(a), FSS quotation procedures are not considered negotiations or source selections. You do not need evaluation plans, scoring sheets, or competitive ranges. Keep it simple.
Do not skip the competition step. Even though GSA schedules are pre-competed, GSAM 538.7103-2 requires you to consider at least three FSS contractors for orders above the MPT. That doesn't necessarily mean sending out RFQs — if the requirement is clearly defined and priced, you can survey three contractors on GSA Advantage, screenshot the pricing, and document your selection. Of course, you can always request discounts from the contractor you select. But you do need to show you looked at more than one option.

5 Documentation Requirements

GSA schedule orders under the SAT don't require heavy documentation. Your contract file just needs:

  • Funding — PR&C, MIPR, or other funding authorization
  • Requirement description — what you're buying (SOW, specs, or a clear written description)
  • Market research — evidence the item is on the contractor's schedule and the schedule is active
  • Quotes / pricing — quotes received or screenshots from your GSA Advantage survey
  • Abstract / award documentation — your best value rationale
  • Delivery order / PO — the actual order referencing the schedule contract number

Check out the File Checklist tab to track these as you build your file.

Keep it simple. For an under-SAT GSA order, a one-page email RFQ with a clear description of what you need is perfectly fine. You're not running a source selection — you're placing an order.

6 Common Mistakes

  • Ordering something that's not on the contractor's schedule. Verify it's actually available on their schedule contract before placing the order.
  • Not verifying the schedule contract is still active. Schedules expire. Always check GSA Advantage or eLibrary.
  • Skipping competition for orders above the MPT. "It's GSA, I don't need to compete" is wrong. GSAM 538.7103-2 still requires you to survey or solicit at least three FSS contractors.
  • Doing too much paperwork. An under-SAT GSA order is not a source selection. Don't create work that the GSAM doesn't require.
  • Treating quotations like offers. FSS quotations are not offers. You don't need evaluation plans, scoring sheets, or competitive ranges. Keep it simple.
  • Overcomplicating a clearly defined requirement. If you can find it on GSA Advantage at a fixed price, you just need to survey three contractors — not publish an RFQ. Use the simplest method that fits your situation.

Walkthrough Scenario

Your shop needs 50 ergonomic office chairs for a building renovation. The estimated cost is $35,000.

This is above the micro-purchase threshold ($10,000) but below the SAT ($350,000). The chairs are a clearly defined, fixed-price item — so you can use the simplest competition method:

  1. Go to GSA Advantage and search for ergonomic office chairs that meet your specs. Find at least three schedule contractors with pricing.
  2. Screenshot the pricing from each contractor. Compare on price, delivery timeline, and whether they meet your requirements.
  3. Select the contractor offering the best value. You can contact them to request a discount — it's a permitted practice.
  4. Place the delivery order referencing their schedule contract number.
  5. Document your file: funding, requirement description, your GSA Advantage screenshots, your selection rationale, and the order.

Contract File Checklist

What you should have in your file for an under-SAT GSA schedule order. Check them off as you go.

GSAM 538.71 — FSS Ordering Procedures

The ordering procedures for GSA Federal Supply Schedules. Under the RFO, FAR 8.4 points here. This is where the actual rules live now — MPT, above-MPT/below-SAT, and above-SAT ordering.

Open GSAM 538.71

FAR 8.4 — Federal Supply Schedules

The FAR subpart on GSA schedules. Post-RFO, it's been streamlined to a single section that directs you to GSAM 538.71 for ordering procedures.

Open FAR 8.4

GSA Advantage

The official GSA online shopping system. Search for FSS contractors, verify contract numbers, survey pricing, and place orders.

Visit GSA Advantage

GSA eBuy

Post RFQs to FSS contractors electronically. One of the four competition methods under GSAM 538.7103-2 for orders above the MPT.

Visit GSA eBuy

GSA eLibrary

Search GSA schedule contracts by contractor or product category. Verify schedules are current and confirm the item is on the contractor's schedule.

Visit GSA eLibrary

FAR Part 8 Deviation Guide (RFO)

The official RFO deviation guide explaining what changed in FAR Part 8 and where the ordering procedures moved.

Open Part 8 Deviation Guide