GAO’s Ares Enterprise decision shows that BPA flexibility has limits. An order must fit both the competed scope of the BPA and the successful vendor’s underlying Federal Supply Schedule contract. For contractors, vehicle access alone is not enough: labor categories, Schedule scope, CTA structure, and the allocation of performance must support each downstream order.

DoD’s use of Intergovernmental Support Agreements increased from 45 in 2018 to 316 in 2025. GAO found that public partners sometimes use private contractors and that the Service Contract Act does not apply to the IGSA itself. The trend could change competition for installation services, labor economics, subcontracting opportunities, and how DoD measures claimed savings.