Anytime the Defense Department hires another federal agency to do procurements for it, those servicing agencies are now responsible in regulation for ensuring that the General Services Administration schedule orders they place on behalf of the DoD comply with Defense regulations.
The new regulation--part of an interim rule made effective Dec. 13 and so subject to change (although, if past experience is anything to go by, minor changes)--settles an argument among federal agencies about how far regulations from the original customer agency penetrate past the level of another federal agency hired to perform procurement services. The answer is all the way.
The rule, in fact, applies to the entire government, but the Defense Department is the federal agency with the most involved set of department-specific regulations and so generally the most likely to have a difference from federalwide regulations. The new rule specifically states that the contracting officer placing the order is responsible for applying the regulatory and statutory requirements of the agency for which the order is being placed. The same goes when establishing a GSA blanket purchase agreement. The new language is part of a revised Part 8.404(b)(1) of the Federal Acquisition Regulation
-David Perera, FierceGovernmentIT.com