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Chapter 6 › X.D.2 Additional Contracting Considerations

Can we use standby contracts, cooperative purchasing or another agency’s contract?

FEMA term
Pre-positioned contracts; cooperative purchasing; piggyback contracts
Short answer

Pre-positioned (standby) contracts work if they were competed under federal rules and cover the work performed. FEMA advises against cooperative purchasing and piggyback contracts because they often fail federal procurement requirements.

What FEMA requires

FEMA reimburses reasonable costs under a pre-positioned contract if:

  • It was originally procured in compliance with federal requirements;
  • Its scope of work covers the work performed;
  • The work was eligible; and
  • The contract term covers when the work was done.

If you use a cooperative purchasing program, you must document how its use complied with all procurement requirements. Joint procurements, where two or more entities run one solicitation together, see fewer compliance problems.

Documentation

The original solicitation and award for any pre-positioned contract, and a written compliance analysis for any cooperative purchase.

Watch out · Govstar practitioner advice

A piggyback contract was competed for someone else’s needs, so its scope rarely matches yours. Compete your own pre-positioned contracts before disaster season.

Govstar summarizes FEMA’s Public Assistance Program and Policy Guide in plain language and links to the official text. Govstar is independent and not affiliated with FEMA. This is general guidance, not legal advice.