Do you have a Schedules-based Blanket Purchase Agreement (BPA) based on a contract that’s about to expire?  GSA rules (FAR 8.405-3(d)(3)) specifically prohibit BPA’s living on after the end of the Schedule contract on which they’re based.  What’s the down-side?  Every invoice your company submits in such a scenario is a violation of the Civil False Claims Act. In addition, you could easily end up with an upset customer that has to cancel a project in the middle of fulfillment if anyone catches on that work is being done against an expired contract. On the other hand, GSA does allow task orders to be issued on the last day of a contract and even gives you and your customer 60 months to complete the work (52.216-22 Indefinite Quantity).  This situation is admittedly confusing, but confusion is not a defense against an audit or whistleblower claim.  It is vital to have BPA awards and extensions reviewed to ensure that the term of the BPA is consistent with the term of the underlying contract.  GSA rules do not allow a BPA awarded under on Schedule contract to be transferred to another Schedule contract, even if it’s with the same company.  That’s called a “new procurement” by the government, even though it may seem to make sense from a business perspective.  Don’t end up on the next edition of “Stupid Contractor Tricks”, make sure your company stays in compliance.