Is a “blanket approval” authorizing multiple change orders compliant with federal procurement requirements?

Federal procurement regulations neither authorize nor prohibit recipients from approving multiple change orders in a single “blanket approval” action. Although this action is not specifically defined under federal procurement standards, approving multiple change orders in a single “blanket approval” would generally be discouraged, but is not prohibited. There may be situations in which such an action may be reasonable and appropriate. It is important to note that Federal procurement requirements do not explicitly recognize a contractual action termed "Blanket Change Order Approval." If a transit agency’s applicable state and local procurement regulations or policies allow for blanket approvals and the procurement official followed the applicable regulation or policy, then the blanket approval could be a valid procurement method for that particular transit agency.  A transit agency using a blanket approval should identify its authority for doing so in the blanket approval and include the document in the project file.   Likewise, if a transit agency’s procurement regulations or policies do not allow for or address blanket approvals, then a blanket approval would not be a valid procurement method.