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This isn't right. The SSAC has two distinct functions: So when using LPTA, the SSAC could still be useful to ensure the SSEB followed the evaluation criteria consistently. Or seek a waiver:

Observation. "Sole Source" is defined in the RFO at Part 2 so the term applies as defined throughout the FAR (RFO). So I could agree that the "limited source justification" is no longer an appropriate term. However I am concerned, of sorts like you, that folks must draw a conclusion that the approval levels for a sole source, a subset of Exception to Other Than Full and Open Competition, is that as stated in FAR Part 6. This is especially true where GSAM at 538.7104-3 explicity states that FAR Part 6 does not apply. If the intent is to have the approval levels be in concert with FAR (RFO) 6.104 then it would seem that the GSAM language should state that FAR (RFO) Part 6 does not apply "except" when doing a sole source. As an aside if I were other than GSA I would not look to GSAM Part 506 for approval levels for a sole source I would be looking at that which applies to my agency. Something like this. First the FAR (RFO), then the agency supplement or policy.

Within the DoD Source Selection Procedures, it doesn’t explicitly state that LPTA is exempt from a SSAC, but without a comparative analysis, there is no role for the SSAC. What are you doing within your organizations? Are you not requiring an SSAC for LPTA? I believe the Army and Airforce clarified that it doesn’t apply, but their is no clarification for general DOD.

In reviewing RFO FAR subpart 8.4 and GSAM/R 538.71 yesterday, I observed two changes from the current FAR that I haven't seen discussed elsewhere: The term "limited source justification" is apparently being retired and replaced with simply "sole source justification." I think this is a mistake, as the former is a term of art that tells the experienced practitioner which procedures apply, but the latter is a generic term commonly used by practitioners to describe any justification for proceeding without competition regardless of the applicable procedures. There are no longer any designated approval authorities for sole source justifications exceeding the SAT. GSAM 538.7104-3(a) specifies that the CO is the approval authority for acquisitions that do not exceed the SAT, but 538.7104-3(b) is silent regarding acquisitions exceeding the SAT. I assume this is an oversight and that the approval authorities will eventually match those found in RFO subparts 6.1 and 16.5. But it would be a glaring oversight. Has anyone else here noticed these oddities? Does anyone have additional insights into them?

For a FAR supplement example, DARS 5815.406-3 includes tables referencing various agency templates depending on the FAR part used.

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The original poster has not been heard from in almost two weeks. This thread will be closed if they do not respond by Wednesday.

Career management has always been challenging, but 2025 brought shock, uncertainty, anxiety, and discouragement to the task for almost all of us who have pursued a career working for and with the federal government. We may face more and even greater such challenges in years to come. Those challenges may include war. We could use a little encouragement, which is why I have made this post and attached to it two of the most inspiring career stories I have ever read. Attached are the texts of two lectures given to the American Council of Learned Society, both entitled, A Life of Learning. They were parts of the Charles Homer Haskins Lecture series, which have been given each year since 1983. The attached lectures were given by two very great scholars and authors in very different fields. The first was by the late Annemarie Schimmel, who was a scholar of religion, an author, and a professor at Harvard and other universities. The second was by the late Helen Vendler, another Harvard professor and a renowned literary critic, teacher, and author. I found these two lectures, in which each speaker described her life’s work, to be very inspiring. Neither speaker had been privileged in life. Both worked hard out of a love of learning, dealt with life and career obstacles and setbacks and, in their cases, struggled against academic prejudice against women. (At Harvard, when Vendler was finally admitted as a graduate student, the English department chairman told her, “You know, we don’t want you here... we don’t want any women here.”) Schimmel faced similar discrimination at Harvard. But both pursued what would ultimately be rewarding careers of study, teaching, and writing, because they loved learning. These and other Life of Learning lectures are freely available at the American Council of Learned Society website: https://www.acls.org/ We in contracting make and manage the administrative and business arrangements needed by the organizations we support to obtain the materials, supplies, systems, services, information (“data”), and construction they need to accomplish their missions. To do that well we, too, must become learned in our field. We must go beyond OJT and official online courses. We must pursue lives of learning. I was lucky to have been taught by my superiors and colleagues at what was the Air Force Space and Missile Systems Organization (SAMSO), now the Space Force Space Systems Command (SSC), and by Professors Ralph C. Nash and the John Cibinic of The George Washington University. I faced nothing like the challenges faced by Professors Schimmel and Vendler. My greatest challenge was my own immaturity, sloth, and stupidity. I hope you will read, enjoy, and find inspiration in the stories of these two intrepid, learned, and successful professionals. What professional challenges they faced and overcame! What professional lives they led! Haskins_2001_HelenVendler.pdf Haskins_1993_AnnemarieSchimmel.pdf

Can you provide an example? I don't think I've ever seen or heard of a FAR supplement prescribing the form that a price analysis must take.

This is a question better suited for your Contracting Officer. Your agency FAR supplement or local procedures should prescribe what form of price analysis documentation is required based on dollar thresholds and governing FAR part (e.g., Price Negotiation Memorandum (PNM) for part 15 vs. Price Fair and Reasonable (PFR) memo or other streamlined documentation for part 13). An abstract is only required by the FAR for part 14; however, the term abstract is commonly used to describe any basic record of quotes/offers received which could be combined with price analysis serving as your determination of a fair and reasonable price. Without knowing what FAR part governs and what your agency supplements/local procedures prescribe, this question can't be answered without additional info.

What is a “PFR”?

We hope you had a wonderful holiday season filled with time well spent with friends and family, moments of rest, and opportunities to recharge. As we step into a brand new year, we’re excited about what’s ahead and grateful to be back into the swing of sharing insights and updates with you. We took a short pause from our Friday Week in Review over the past few weeks to enjoy the holidays and as a result, today’s edition features more articles than usual. There’s plenty to catch up on, so grab a cup of coffee and take your time exploring the stories and insights we’ve gathered for you. Have a great weekend! Stories from this week include cybersecurity and AI updates, and what to expect in 2026. Five things to watch in cybersecurity for 2026 CMMC Phase 1 Is Here: What Defense Contractors Must Do Now AI-Assisted Acquisitions Demand Data Sharing NDAA: Massive expansion of commercial solutions openings and other key takeaways for defense contractors How Do New GovCons Stay Compliant From Day One? Bipartisan bill seeks to create joint DoD–VA credentialing system Congress Reorganizes Key Federal Contracting Laws Under Positive Law Codification Overhauling acquisition, production and procurement processes to rebuild the industrial base Federal agencies look to performance contracts as energy efficiency aid shrinks DISA’s push for acquisition accelerators buoyed by FAR update Air Traffic Control Overhaul Heats Up as US Government Awards Contracts No slow rolling for defense contractors as 2026 gets started Concerns persist over self-reported cyber readiness as DoD overhauls workforce management Defense Department unable to pass its annual audit, again OPM to hire critic of HR consolidation plan FAR: New Procedures for FOIA Requests Acquisition more than IT drove the news in 2025 Agencies Cancel 55 Contracts Worth $863M in Cost-Cutting Effort The post SmallGovCon Week in Review: December 22, 2025 – January 9, 2026 first appeared on SmallGovCon - Government Contracts Law Blog.View the full article

This reminds me of something I read from a senior manager. He stressed how important empowerment, training, and trust is. The gauge he uses for his personal management performance on these areas is his golf score. When he has sufficiently trained and empowered his subordinates, he can take off a lot of time for golfing. He doesn’t need to worry about the job not being done and his golf improves.

THE WHITE HOUSE, January 7, 2026 Executive Order: Prioritizing the Warfighter in Defense Contracting The White HousePrioritizing the Warfighter in Defense ContractingBy the authority vested in me as President by the Constitution and the laws of the United States of America, it is hereby ordered: Section 1. Purpose.

True, but trust is not enough. You must commit to its nourishment and well-being.

We also need buy-in and trust from senior leadership. During my active duty time at Ft Hood one of the Director's monikers was Empowerment. But we were never really empowered due to policies on top of policies. See that warrant hanging on the wall, that is all it is....a wall piece. So 100% agree with everything stated thus far, but there also needs to be trust in your workforce in order for it to work.

We track it in excel. We track it in teams. We track it in a useless center wide database that is only flagged for compliance once a year and is never looked at. We track it in biweekly meetings. We track it in KTfileshare. Let me count the ways we waste our time.

The "right people". The deep-learners, hard-chargers, risk-takers, and OODA loopers.

Great article, Vern. Thanks for posting it. I hope a few read it, get motivated, and change their outlook on their jobs a little differently. This excerpt is a compelling message for those seeking employment and for managers seeking the best hires:

I'm a prophet. Just announced: "Service acquisition leaders: Why this time will be different for defense acquisition" https://breakingdefense.com/2026/01/defense-acquisition-reform-dale-white-robert-collins-army-seiko-okano-navy-stephen-purdy-space/ Excerpt:

There’s no better advice for those interested in advancing their career. Right now there’s a mass of confusion out there. The workforce is largely risk adverse. It looks for regulations to be broken down into detailed instructions and precise steps to be take. The majority want to physically see what works so they can copy for their assigned tasks. So not much has happened thus far with the RFO. A few hopefully will see the light. They will do as Vern states - study, learn, and explain to others. I’ll add they will seize the opportunity to apply the revised process to newly selected contracting assignments. They do this before all the policy, analysts, and writers of procurement instructions spend months producing something. They then become the “experts” others turn to including the policy writers. The bulk of the workforce needs led with examples and told the steps to follow. I think that’s largely due to the risk adverse environment created. 25 years ago, Performance Based Acquisition was in vogue. Despite the push to adopt it, not much initially happened because people waited for someone else to take the lead. The company I worked for had knowledge and experience in helping craft the Seven Steps process. Once the word got out we could assist, we had to turn away work due to the demand. The 1102 community wanted someone to tell and show them how to proceed. Another example concerns when the government tried Zero Based Budgeting. Few at the operational level knew what it was about. A newly hired young employee became interested and read, studied, and asked questions. Despite her age, she quickly became recognized as the expert. She saw what’s needed to be done to succeed from that experience and advanced applying that same inquisitive nature to everything she did. She rose to an SES position within record time. To address Carls point, it’s more than just being nimble and flexible. It’s grasping beneficial concepts, studying and inquiring, developing insights and understandings on what needs done to apply, and taking the lead in doing the work as well as continual application throughout your career.

No, but expect the unexpected. What I will be watching for is what contracting personnel actually do after the RFO is complete. What procedures will they adopt, and whether those procedures make acquisition more timely and effective? I just read a GAO decision about the issuance of a $75.5 million task order for IT support services against a MATOC under FAR 16.5. MATOCs were the product of the Federal Acquisition Streamlining Act of 1995. The request for task order proposals was issued in July 2024, the agency got six proposals, the award decision was protested, and the GAO sustained the protest in December 18, 2025 See Solvere Technical Group, B-423785, 14-page decision: A year and a half to solicit, receive, and evaluate six proposals and settle a protest, and it's still not done. So much for reform, innovation, and streamlining. Clouds appear to be gathering on the international scene, and developments will put pressure on the acquisition workforce. How the workforce responds will affect future legislation, regulation, and managerial reaction, and thus the future of the workforce. The workforce has been through a hard time and times are still tough. Strength, resilience, and ingenuity are the themes of the days to come.

I have difficulty in being as succinct but to me "career" implies something thats reaches beyond 2026. I get the challenges for the next year but to me a career depends on a long term vision which for a Federal employee, and most especially for those in the acquisition workforce, is impacted by politics and the changes, whether slight or considerable, brought about by the politics. So my thought might fit in "get what it is all about" yet I offer this. Those who are flexiable and nimble with a long term vision.

Thanks, Vern. Apart from the FAR rewrite, do you have any specific events in mind?

2026 Careers will be made and broken during the coming year. There will be a lot of uncertainty in the acquisition workplace. Uncertainty about rules and processes and uncertainty about careers. For some, the uncertainty will present the opportunity of a career lifetime. Who are the "some"? Those who are curious., thoughtful, and ingenious Those who get what it's all about and move out sharply in hot pursuit Those who study, learn, and are able to explain to others. Study what? Learn what? Be able to explain what to others? Concepts Principles Rules Processes Procedures Methods Techniques Who are the some? Those who move out sharply! Those who do!