Thanks for the response. To give a little more detail, the no-cost agreement I am contemplating is to establish industry days – where the vendor would do all the coordination/execution of the industry day & charge a fee to keep for themselves.
Please see this answer below – regarding FAR and competition – from GAO FAQs (link included). My question is in relation to a civilian agency.
How do the federal procurement laws apply to an agency’s use of a no-cost
contract?
Statutory requirements for competition, such as the Competition in Contracting
Act (CICA), apply to procurements by federal agencies for property or services.
10 U.S.C. § 2303; 41 U.S.C. § 253. Thus, as a threshold matter, to be subject to
these requirements, the agency must be acquiring property or services.
Determining whether competition requirements apply to a particular procurement for a no-cost contract for property or services will depend on the agency involved.
CICA does not apply to no-cost contracts of military agencies, see 10 U.S.C.
§ 2303; Century 21—AAIM Realty, Inc., B-246760, Apr. 3, 1992, 92-1 CPD ¶ 345;
Gino Morena Enterprises, B-224235, Feb. 5, 1987, 87-1 CPD ¶121, but it does apply
to no-cost contracts of civilian agencies. See 41 U.S.C. § 253; Gourmet
Distributors, B-259083, Mar. 6, 1995, 95-1 CPD ¶ 130. Federal Acquisition
Regulation (FAR) requirements apply only to acquisitions by the government of
supplies or services with appropriated funds. Fidelity and Casualty Co. of New
York, B-281281, Jan. 21, 1999, 99-1 CPD ¶ 16; FAR, 48 C.F.R. §§ 1.104, 2.101.
Consequently, the FAR does not apply to no-cost procurements conducted by
either a defense or civilian agency.
http://www.gao.gov/special.pubs/appforum2008/nocostcontracts.pdf