C Culham

Agree. Always felt so and the RFO supports this position at FAR 12.403(a) and (c). Makes me wonder if the agency has adopted the RFO? And if the agency has adopted the RFO but the contract was awarded pre RFO what FAR guidance applies?

Makes one wonder if, prior to recodifying the FAR to implement the entirety of the RFO such matters will be clarified? Or, will there be the first in an endless trail of circulars? Change will always occur but one would hope the out of the box "new" version doesnot demand immediate correction. Seems "agile, effective and efficient" as a standard is a mixed bag and as they say haste makes waste.

Granted following the regulatory guidance at FAR (RFO) subpart 1.2.

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.

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.

I struggle as well. @KeithB18 I wonder with some very simple examples - Where in the Federal procurement rules does it state that evaluation criteria can not change prior to final source selection? House, maybe not during final evaluation but I have got to think that during what I will term market research. Would it be foolish to consider real estate listings to be similiar to GSA FSS ergo a purchase from an established listing of possiblities? Recent experience with one of my children and his wife as first time home purchasers, I did not step into any of the possibilities but they were shared via emails and I voiced thoughts. Documentation maybe not as a formaility all the time but a mental exercise of the same decision processes. And by my own personal experience there might be the use of the old trick of a pros and cons list. Something I have used several times throughout my lifetime. Legislated socio-economic demands are what sends Federal procurement down its unique path.

My concern is what the garbage in is based on. By example my mind quickly races to the RFO and to date the varying adoption by deviation rate by agencies along with final FAR replacement in total. I struggle with how a requester can be specific and fully detailed in their request when considering the FAR, RFO, FAR Supplements and agency policy that would need to be included in a solicitation/contract. Humans are not perfect at doing it so I struggle that the tool created by humans, AI, can do it any better. I struggle as well with the hidden impact. My life's view has been forever transformed by the multitude of windmills that line the ridges surrounding my home and the behemoth data centers now my neighbors that gulp water from the watershed that surrounds my home. Connected?? In my view yes because it is all a part of the cost/benefit. Very simply stated. In the context of the discussion should it be more AI or an elite special contracting officer corps as the investment to make it (Federal acquisition) better or even best?

So the new question has strayed us off topic but I will bite anyways. In the beginning I was not bewildered. Challenged maybe to explain to the requisitioners how to navigate GSA for their market research efforts. Today yes complicated by the width and breath of growth in GSA Purchasing Programs and as formerfed notes GSA's efforts to stay viable as an acquisition service for the Federal government. While my actual experience has waned I do get the feeling that in the context of educating the acquisition workforce regarding GSA Purchasing Programs is nothing like it use to be. PS - I still have it. And it is a GSA Certificate of Training 10/3-7/1977 "Small Purchases/Federal Supply Schedules". No research on my part but I wonder in FAI's FAC-C what is comparable today?

Your full statement was this (emphasis added). So the vehicle to be used dictates whether to setaside or not? Seems inconsistent with FAR part 10 and 19. To add use of the agency IDIQ is not generally mandatory. Why is the decision limited to the agency IDIQ, why isn't say AbilityOne, GSA FSS and so on all the way to full and open in the mix. While I would agree the formality of market research is a gut feeling of the CO of where to go I believe formalized or not the steps I described is the suitable approach. My read of FAR part 10, as now definitized by the RFO, suggests strongly that if the acquisition is above the SAT the IDIQ is not automatic, setaside or not. No need to debate further just my view of one more misconception inbred into the world of agency IDIQ's.

Thanks Vern. I struggled to find a place to offer this up when reading past WIFCON posts. But now I can. Back around December 15, 2025 this was announced - "Merriam-Webster names 'slop' as its 2025 word of the year." The "AI Overview" - "Merriam-Webster's Word of the Year for 2025 is "slop," chosen for its surge in usage to describe low-quality, often AI-generated digital content like fake news, absurd videos, and propaganda flooding social media feeds. The word reflects a cultural moment where people are increasingly encountering vast amounts of mediocre, manipulative digital material, leading to significant interest and searches on Merriam-Webster's dictionary. "

Yes

I might nitpick this and hopefully responds to the original posters questions as well. I would suggest the CO in doing "some level of research" would go something like this. CO in doing the research determines that for the need whether two or more SDVOSB's can provide fair market price for the delivery (timely) of all the item(s). If this is determined a Full and Open Competition after Exclusion of Sources (see FAR 6.206) is appropriate and the CO decides to solicit only SDVOSB's. The CO does not do a formal justification or determination and finding but does document the file to whatever extent the CO feels is necessary to support a decision to setaside for SDVOSB. With the decision made the CO then decides if there is an existing tool, such as the agency's IDIQ, to do the setaside or if they need to solicit the entire market of SDVOSB's for the item(s). Essentially the decision to setaside or not leads to the tool, process, method or whatever you want to call it to make the acquisition. So directly to the new questions - Yes all the Task Orders are by default setaside because the CO is using a tool that was setaside, etc. that has only firms on it that qualify for the setaside. Once again clarity is needed and the specific language of the IDIQ would be helpful. Additional thoughts. Are you saying that the only entities being solicited for the need are those on the SDVOSB IDIQ? Or has the agency gone to those on the IDIQ as a matter or courtesy since the need is within the NAICS? I ask because remember a determination to setaside or not is based on competition (two or more at fair market price) along with quantity and timely delivery. It could be that the CO's research couldn't really determine whether all on the IDIQ could meet price, quantity, delivery so going out to those on the IDIQ and those that are not is a form of market research. Get the quotes and if an entity on the the IDIQ says they can meet the need they could get the award of the need outside the IDIQ. The twist comes at award. Let me see if I can further clarify.. Properly if the need was not setaside then tying the award to the IDIQ as a Task Order is not proper in my view. Remember the reference to FAR Clause 52.216-18? Remember that the clasue says all task orders are subject to the terms and conditions of the parent IDIQ contract. The parent contract was setaside, correct? So if the CO did not setaside the need but found that an entity on the IDIQ could do it and awarded to them they should award the procurment outside of the IDIQ and so the SF-1449 should show it was not setaside. Bottomline the CO does not have to use an IDIQ when a decision is made to setaside but can as a matter of efficiency. Likewise the CO can solicit from those on an IDIQ if the competition is determined to be full and open but award would not be made pursuant to the IDIQ but to a full and open competition. Confusing I know but once again I hope I helped.

Let's see if I can unpack the issues with some general comments. Generally speaking a Task Order can only be issued to those holding a IDIQ. Under this general rule consider FAR Clause 52.216-18 that would usually be found in the parent IDIQ contract. Also consider FAR 16.504(a)(4)(iv) where "awardees" of the IDIQ are be given a fair opportunity for consideration of orders. This said I guess one could imagine an agency doing something very unique and place language in a IDIQ that would allow award of a Task Order to other than a holder of the IDIQ. It would in my view be very complicated to do so and I have never seen parent IDIQ contract language allowing it. Yet I have learned over time to never say never. To the point of SB setaside or not I have this gut feeling in reading your original post that all the facts are not present and that some how the matter reaches to something similiar to this GAO protest so I am offering as reference for you to read. https://www.gao.gov/assets/b-419167.pdf#:~:text=DIGEST.%20Protest%20alleging%20that%20a%20procuring%20agency,task%20order%20issued%20under%20a%20multiple%2Daward%20contract. Bottomline for me is one specific fact unknown and that is what are the specific terms and conditions of the parent IDIQ contract. I say this because of this quote from your post "determining which contractor should receive a task order" because in my read of FAR 16.5 "contractor" in my view is implied as being a contractor that holds the indefinite delivery contract not just any contractor. Hope this helps.

@Moderator I actually donot disagree with this quote. However I don't think I penned it. I could be mistaken. If there is a way to give due credit to the author or correct my memory I would appreciate it. Thanks!

Sorry I wasn't clear. The agency I worked for had it all but would not support it's use beyond the requisition and contract writing aspect. By support investing in training, etc. for vibrant use. Easier to buy administrative systems for what many view as the routine effort to do acquisition. I think viewed as less expensive than hiring and retaining a broad spectrum acquisition staff (1105, 1106, 1101, 1102) as well. But that is an old tune! I wonder if it's more fun to learn PRISM than it was to learn contract negotiation. Oh, well. AI will take over what's left of 1102 work.