Modification to BPA SOW to allow PII information

Why can’t you modify proposed, unfinalized Blanket Purchase Agreements  ?? Get it straight now, not try to amend multiple BPA’s  later. Some players might not agree to amend the terms their agreement or may withdraw prior to finalizing the agreements. 

BPAs are not contracts but agreements to use to solicit purchase orders.

I would issue an amendment to your solicitation to modify the language in the SOW and request revised proposals. Handling PII requires additional steps and safeguards to mitigate unauthorized exposure. Most agencies have supplemental terms besides FAR Clause 52.224-3 Privacy Training (Jan 2017) that must be included in solicitations and awards when a Contractor might have access to PII and/or SPII. Said terms require the Contractor to not only take privacy training, but also outline steps to respond to a breach and potential penalties. All of which introduces risk which a Contractor will need to factor into their business capture decision and their pricing. I assume the BPA is for commercial products and/or services? Then any change would need to be bilateral per FAR Clause 52.212-4(c). Some of your newly awarded BPA Holders may not want to take on the additional risk and refuse the modification. Others may expect significant consideration for this change. 

Amend your solicitation now and iron out this revised requirement before you make the awards. Otherwise you may end up in a very expensive and tricky position. Your negotiating leverage is always stronger before you make an award.

PII is not an administrative issue and likely would involve multiple, high-level agency reviews and approvals.   That's a heckuva' last-minute add.