C Culham

The 1102 series is by definition a professional series. 

What I believe is not true is that someone that occupies an 1102 position possess the characteristics of a professional but I would offer that by personal experience many do.

I am confused by the discussion in this thread as it is true that not all 1102 contract specialists (1102) are Contracting Officers (CO).  Yet the words CO are being used interchangeably when discussing what professional work is.  This is where the confusion is as I believe there are salient differences between the two titles beyond the fact of legal authority that is vested in a CO.   In the medical field an intern, resident and attending physician are all professionals yet level of responsibility and autonomy are the difference are they not?  So why can it not be the same with regard to 1102 to 1102 and then to CO?  And if the same does not it change perspective of devotion as well yet this statement

On 3/5/2026 at 7:36 AM, Vern Edwards said:

You are a professional, or not, depending on how you live your work and prepare yourself to live it.

still rings true?

27 minutes ago, formerfed said:

On the reverse side, the standards for a purchasing agent need revised to reflect what goes on with placing orders today versus decades ago where a GS-07 or 09 often tops out.

Just as aside. I found this in the last couple of days when doing research regarding threads in Forum. I am always intrigued about how long some topics have been discussed but never resolved. 8 years or more for 1105's and even AI!

16 minutes ago, Vern Edwards said:

Ah... AI entries, or AI inspired. Well, if we're going to do that, here's another:

No sir. My inspriation!

Here are some but not all of the references I had encountered in the past when going back quite honestly to the history you posted about professionalization of a GS series to stuff I encounter through to today. Such as the what is the basis behind professional General Schedule classification standard. Various editorials by folks like Indeed. An orgainzation www.psychologicalscience.org And the US Department of Labor as demonstrated by this https://www.dol.gov/agencies/whd/fact-sheets/17d-overtime-professional NCMA Standards and Practices. All references that in my casual but continued experience over fovever as a professional that I encountered that addressed a professional worker. I will say as I reached back I did encounter the typical AI responses but I did not stop there but went on to find what I thought I had encountered and read before. My inspiration that found the references.

7 hours ago, Vern Edwards said:

What is the distinction between professional and other work?

Professional work requires advanced specialized knowledge of a subject with that knowledge acquired through education above the level of high school with education/experience continuing in the particular field.  Other work does not.  Professional work is nonroutine work that is intellectual in character where other work is routine mental effort.  Professional work applies the intellectual knowledge to grasp, analyze, and communicate complex and abstract ideas.  Other work does not. Professional work requires high ethical standards and integrity and might be supported by a certification or license.  Other work does not yet might be supported by some type of certification or license such as skilled labor.

4 hours ago, Vern Edwards said:

What personal characteristics distinguish professionals from other workers?

Personal characteristics of a professional are reliability, organization, empathy and emotional stability.  Accountability for actions, ability to change, positive attitude and a strong adherence to ethical work are also characteristics of professional workers. Other workers may demonstrate some of these characteristics but at lower levels.

6 minutes ago, Vern Edwards said:

All the RFO is doing is requiring that a determination to procure from a single source have a specific content presented in a specific order. I think it's a helpful change, especially if your determination might be challenged.

But I know better than to pursue this further with you. So thanks for your response to my question. I'm moving on.

Thanks. I understand your view.

History shows as well that agencies turned a determination into a JOFOC. Time will tell if they feel compelled to make more of a D&F than there needs to be. RFO 1.5 allows them to.

And we have not even touched on the other change noted in my original comment. RFO 12.102. No D&F, not even a determination just "document". If a D&F is good standard for RFO 13 then I would think a good one for RFO 12.

I am moving on too.

44 minutes ago, Vern Edwards said:

@C Culham Do you believe that requiring a D&F to support a single source procurement under Part 13 somehow brings CICA and full and open competition into the simplified acquisition process?

Not statutoryly.

Yes regulatory and by ill-advised policy. My example. Currently a if solicitation and its processes talk like and look like FAR part 15 even though to be claimed to be otherwise by calling it a quote, GAO by case law history usually views it as a RFP. Make a single source look like a CICA exception by use of D&F, JOFOC, and possibly higher level approval its no longer a determination. It becomes as defined by the now RFO as a D&F and what agencies do beyond.

My question outside of Don's query is - What common sense has the RFO brought to Federal acquisition? Time will tell I guess.

18 hours ago, Vern Edwards said:

Most of that is merely descriptive and explanatory. The substantive text is in 1.504, Content. I presume that agencies generally require that such determinations be written and filed in light of the fact that (1) they can be protested (see the attachment) and that (2) the GAO typically rejects after-the-fact justifications. The new D&F requirement and content instructions seem helpful. And I would assume that contracting officers that conduct simplified acquisitions would scan Part 13 to look for changes.

Might it open the door to "one source" class determinations?

But I could find nothing in the RFO materials that explains the change.

Here is my view of the change.

The FAR left it to a determination, no structure, but something as you note would be in writing to document the file. As to GAO and rejecting after the fact determinations it does not look like it was an issue that needed fixing. My reference is a quick scan of GAO decisions regarding FAR 13.106-1(b) and this - https://www.wifcon.com/pd13_1061b.htm

The RFO now requires a Determination and Finding, something more prescriptive. Is doing so really more efficient and economical? Consider the discussion found elsewhere regarding bringing back 1105's. They will have a warrant up to the SAT and by experience of the days when 1105's were around the 1105's would not be left to making such a "determination" on their own. And then there is this, the example of one agency turning a "determination" into a full fleged JOFOC! https://www.fiscal.treasury.gov/files/doing-business-with-fiscal-service/SF1009.pdf I would offer this agency is not the only one that applied FAR Part 6 prescriptions to FAR part 13.

I think the door was already open for class "determinations". Changing to "determination and findings" is a change of structure and prescription on how to do it not that it was not already allowed.

I have a concern that is based on the fact CICA does not apply to procurements equal to or under the SAT which both the FAR and now RFO validate at 6.001. Now it has been slipped in to RFO 13. The RFO now stretches to part 13 a requirement that which is common for RFO part 6 exceptions. This concern poses a question for me - Will agency's move away from JOFOC's with this change? I will not bet on what they do as they never "got it" before!

In the end the change is what it is but I personally do not view it as consistent with CICA or case law but something someone brought to the table because they think it is more efficient and economical to be prescriptive. Beyond common sense in my book!

@Jamaal Valentine Sticking just a minute to RFO 12 I forsee another issue with regard to the final rule making. Even with study, reading and thinking to accomplish the full grasp of what the changes are by a CO (broad term for agency acquisition folks) what about those outside of the loop. Those that have been trained, counseled, informed or whatever as to what is needed to make an acquisition happen. Consider my example offered - If it is non-commercial item at or below the SAT give me a D&F as to why only one source is reasonably available. Pursuant to the FAR something never required before now it is! I know some agencies did require the D&F but not all.

How about breaking a procurement into smaller elements to avoid statutory requirements. A no-no it seems that has been preached. Not a hard rule when it comes even the (old) FAR but now how about this interpretation in the "FAR Companion Version 2.0" (page 31) - "FC 12.201 Modular acquisition strategies. Consider breaking large, complex requirements into smaller, independently procurable components that align with how commercial markets naturally organize products and services." In truth FAR to RFO wording of 12.201 has not changed but it just struck me that the implied allowance put forth by the Companion interpretation has. But then again if I was a true practioner I would have carried this interpretation with me since day one of the FAR part 12.

Leaves me wondering again about the strategy of FAR to RFO to Deviations to Final Rule. Just give me the final new rule(s) and as noted let me read, study and apply because does it really matter about what I could not do or do in the past just let me concentrate on the here and now and future.

1 hour ago, Vern Edwards said:

Why not?

Should an American company refuse to sell its products or services for use as components of weapons that the agency tasked to defend America needs?

Should Ford motor company have refused to manufacture tanks during WWII?

Should the companies that made the components of the atomic bombs dropped on Hiroshima and Nagasaki have refused to do so?

Should the government employees working to develop weapon systems refuse to work on such programs?

If there's a line, where do you draw it?

I'm asking, not announcing an opinion.

Are you saying efforts related to World War II and the War Powers Act of 1941 provide a premise that Anthropic can not or should not say No? Not strong examples in my view because it is a different era and different circumstances today. Folks are saying no in all kinds of ways to the efforts of the government (Congress and the Executive Branch specifically ) today. And each of the branches are saying no to each other as well in all kinds of ways. The line is politics today and has nothing to do with the survival of a nation in a declared war of yesterday. I wonder what Anthropic would be saying if it was yesterday?

1 hour ago, Vern Edwards said:

If that's all you've got to say, why post it? Everybody knows that in America, a juristocracy. Lawyers ultimately decide all such disputes.

Why post your question since "Everybody" knows where its heading anyway or are you saying that posts by individuals in Forum will be the lynch pin where the courts won't have to settle it and Anthropic will simply capitulate? I do not think so because it is more about politics ( have you read statements by several elected representatives that support Anthropic's position?), strength of the presidency and on the flip side corporate philosphy that is ultimately the bottomline and probably much more. As implied by my statement above but stated this way, some people and the entities they represent believe it is necessary and some don't and it is therefore left to adjudication to solve the conflict of DPA's use.

8 minutes ago, Vern Edwards said:

Can Anthropic refuse?

Sure why not.

8 minutes ago, Vern Edwards said:

Can the Defense Production Act of 1950 be used to force them to sell their product to DOD for lethal purposes?

The courts will decide.

9 minutes ago, Vern Edwards said:

Should an American take the position that Anthropic has?

From a corporate view I suspect Amercians do all the time. What gets me is they argue about lethal harm but AI is causing harmful and destructive damage in all kinds of places. Anthropic for instance is accused of causing such harm in the world of music. Call me simple but I am going to guess lack of control (Anthropic was hacked by China were they not?) in this new world of AI any entities AI is going to get used for lethal purposes. The stance could be viewed as admirable by some but what is the real reason behind it?

15 hours ago, Don Mansfield said:

What are contracting officers required to do post-RFO that they were not required to do pre-RFO?

Write a Determination and Findings pursuant to RFO 1.5 when soliciting from a single source for a noncommercial service or product that is valued at or below the SAT.

15 hours ago, Don Mansfield said:

What are contracting officers not required to do post-RFO that they were required to do pre-RFO?

Determine only one source is "reasonably available" when restricting competition to one source for a commercial service or product at or below the SAT..

@InquisitiveSDVOSBer

See FAR 19.302 or RFO 19.201-2.

As to verification I have considered your original post as truth, that is the firm has updated their SAM.gov profile to reflect their "other than" status so a CO in fulfilling their verification obligation would clearly see the firm is not small. So again if the CO has errored you can call them out on it. If you qualify as an interested party call the CO out by protesting. If you are not an interested tell the CO anyways and hope they take heed. If the CO doesn't take heed call their IG, your congress person or use some other drastic action to get the COs attention.

Your facts suggest strongly the CO should doubt the status of the firm. Get the facts to CO!

Additional references FAR 4.1103 or RFO 4.304. Note the word "must". Any suggestion that a CO should not check SAM.gov at award of an order or extension of a BPA is lame.

1 hour ago, InquisitiveSDVOSBer said:

But nothing I can find says that a Contracting Officer "must" verify a small is still small every time an award is made under a BPA, prior to awarding - is that written anywhere?

In my view a CO would be remiss, and most likely is not following proper efforts to determine eligilbility for award, if they do not at each order confirm the the size certification provided by the firm. Likewise it is my view that a CO would not be following proper efforts at renewal of the BPA on an annual basis. (Reference - FAR 13.303-6 or RFO 12.201-1(e)(3)).

This said I could see where a CO might not do so for all kinds of reasons. One could be that they do not understand the regulation to do so.. If me and I were to believe that the there is reason the CO should question the certification for a BPA and/or order I would inform the CO of the matter. If the CO continues the BPA or an order with the contractor after being informed of the issue of small business eligiblity and there was conclusive evidence that the entity is not a small business a protest to the CO (not SBA) by an interested party could be made. (References - FAR 33.101 or RFO 33.102)

I believe the answer to your questions can be found either specifically or by interpretation of a full read of 13 CFR 121.404. I am providing the CFR reference as it will be the default regulation if the matter reaches SBA for a final determination.

3 hours ago, zmahshie said:

This appears to be a fairly recent change - has anyone else encountered this? If so, have you found a workaround to get the 8a certification to appear in SAM.gov? Or is there an alternative to demonstrating 8a certification for a JV that you’ve had success with?

A JV for pursuing sole source 8(a), competitive 8(a) or both? Noting as SBA still approves for sole source. Reference - https://www.sba.gov/federal-contracting/contracting-assistance-programs/joint-ventures

And then there is this. Pay attention to the discussion about "UEI".

https://buy.gsa.gov/interact/community/6/activity-feed/post/4c2720db-e527-4b54-9189-b0aabe9c42be/Joint_Ventures_will_now_be_able_to_see_socio-economic_set-aside_opportunities_in_eBuy

My only other suggestion is to contact someone in the 8(a) Program itself not the help desk as all my research suggests SBA has to help with with letting SAM know the JV is legit.

1 hour ago, Vern Edwards said:

Should the government return to making a distinction between GS-1102 contracting officers and GS-1105 purchasing agents?

Purchasing agents would handle small-dollar transactional buys𑁋such as purchases of simple product buyes, simple services, and small-scale construction

Contracting officers would handle large-dollar long-term relational buys𑁋such as product and software development and production and other complex services, and large-scale construction.

Wouldn't that simplify and reduce the costs of training and make purchasing agent jobs open to those without 4-year college degrees?

Sure why not as it seems such a structure worked in the past just fine. I am not sure it would reduce costs as would it not be an addition to the exisiting workforce unless the suggestion is some 1102 positions would be eliminated with such a change. Yes the college degree requirement is not applicable to the 1105 series.

A 360 move that would open the doors to the question of is there adequate funding to do so (again with the thought that it would an addition to the exisiting workforce) and is such a structure good for this new world. I think it could be with thoughtful thinking.

PS - Did a quick check. Today USAJobs has 12 purchasing agent 1105 positions listed and 69 contracting 1102 positions listed.

45 minutes ago, Vern Edwards said:

Should Congress and the FAR Council repeal all statutes and regulations that mandate procedures for competitively awarding contracts and let contracting officers decide how best to do it?

No, chaos of all sorts would occur.

In an attempt to tie the originial question, re-phrased together, my thought is this. Giving CO's greater latitude to select a method to conducting an acquisition under the current structure of quotes, bids, negotiation inclusive of selecting contractors through a process of evaluating abilities only and then negotiating price/cost makes lots of sense as it would emulate what happens in the world outside of Federal contracting. But, there needs to be sideboards, but what has been likened to essay writing contests surely does not need to be used in all cases where it seems the pendulum has swung to.

2 hours ago, Vern Edwards said:

But is it true?

Yes. By experience for what I will call the acquisition of my personal needs seeking and applying competition does reduce the costs and does increase the quality of what I buy. Yet by experience when competition is done within the structure of the Federal Acquisition Regulations I believe the answer is it depends. Why? Because of the socio-economic and political interests that are mandated by the processes of the Federal Acquisition Regulations and the policies that are invented to go along with Regulations.

10 hours ago, Don Mansfield said:

Let me rephrase that--

Should Congress and/or the FAR Council mandate standard procedures for contractor selection and contract formation, or should they permit agencies to decide which procedures to use within the guidelines of FAR part 13 (for any dollar value)?

This has gotten confusing again. Here (above) is the question of the thread rephased in an attempt to avoid the confusion. I have followed the responses since this re-phrased question and the whole of responses keep going circular. In fact in reading and re-reading and then re-reading again I am honestly lost as it seems new questions have been posed that take the thread in different directions.

For example take this most recent question posed - "Do you mean price has to be an evaluation factor or are you referring to the requirement to determine price reasonableness?" With regard to what is my question now? Are we talking the SAT and is so the FAR or the RFO as I believe the response is different if the FAR or if the RFO.

All said I will keep following the thread as I usually do but I believe it has significantly departed from its original intent.

3 hours ago, Don Mansfield said:

Given SAP allows any combination of procedures from 13, 14, 15, 35, and 36, wouldn't that include Brooks Act procedures?

3 hours ago, Don Mansfield said:

Given SAP allows any combination of procedures from 13, 14, 15, 35, and 36, wouldn't that include Brooks Act procedures?

I do not think so. A read of Part 36 in total reserves the Brooks Act process for A-E by my read. Same conclusion in a full read of FAR Part 13 where A-E is held out a different.

On 2/20/2026 at 8:10 AM, Vern Edwards said:

You don't see many such articles today. Why do you think that is? Is the matter settled?

What is the role of the contracting officer?

The matter of "role" will never be settled as those who attempt to explain confuse role with responsibility as demonstrated by the example artciles. Role is in my view clearly defined in FAR Part 2. That role is to enter into, administer, and/or terminate contracts and make related determinations and findings.

Responsibilities of the contracting officer are myraid. The FAR provides for some of those responsibilities clearly where by example FAR Parts 4, 9, and others have subparts entitled Contracting Officer responsibilities and other FAR Parts imply the responsibilities. Then the FAR muddies the waters with such terms as Administrative or Termination Contracting Officer. Then throw in agency FAR supplements, policy, especially policy with regard to warranting a CO, add in position descriptions and the responsiblities vary. Take this example. While the world has changed consider a Contracting Officer for the SBA's 8(a) Program. The responsibilities included insuring 8(a) participant compliance with 13 CFR 124. The whole 8(a) dynamic has changed with the advent of the Partnership Agreements now used. (Here I can only suggest that one pull up on the agreements and look at the roles and responsibilities delinated.)

Conclusion - The "role of contracting officer" is static. The muddled confusion lies in the responsiblities the Contracting Officer as a 1102 or possibly a other civil service position or a military officer is given beyond that of the FAR.

I think your question digs into the issue of bona fide need as I believe an order processed under the Economy Act is subject appropriation law principles that shape the bona fide need rule. Knowing more details would probably assist in a specific reply. With this said here are a couple of references that may assist you in applying appropriation law principle of bona fide need to your specific issue. One point to remember is that sometimes agencies have policy that is more restrictive than regulation based on statute.

https://www.wifcon.com/bona/bonafide1.htm

https://www.dau.edu/acquipedia-article/bona-fide-need

17 hours ago, formerfed said:

One aspect not mentioned is industry reaction. The majority of contracting money goes to companies experienced in government contracting. They have organizational segments specialized in just doing business with the government with methodologies developed over years of experience. They like the status quo and don’t want the doors opened to others and approaches differing from the standard ways.

I had the same thought as this thread progresses but then I wondered. Industry has accepted FAR Part 12 and the allowance to use SAP up to the $9 million threshold to the point that they defend it have they not? Seems they might embrace the idea of SAP as an option for everything.

I have also weighed Don's question against allowing Brooks Act like processes for all procurements. I struggle to decide what might be of most benefit.

11 minutes ago, Don Mansfield said:

Should eliminate the dollar limitation on SAP?

Yes

16 hours ago, Don Mansfield said:

Let me rephrase that--

Should Congress and/or the FAR Council mandate standard procedures for contractor selection and contract formation, or should they permit agencies to decide which procedures to use within the guidelines of FAR part 13 (for any dollar value)?

At first blush my first thought aren't some agencies doing this anyways with their own unique ways to acquisitions. Example the evolution of what has become an IDIQ.

More specifically FAR Part 12 has allowed this to occur already up to $9 million but it would seem as formerfed notes agenices inability put doing so into practice. I do disagree that industry could not grasp it as I believe that industry does similiar every day. So yes I think Congress and the FAR Council should.

1 hour ago, Vern Edwards said:

Why did you leave out "Congress and/or agency policy makers" and substituter "the FAR Council"?

In my view this is one of the top take homes for the War Department on acquisition reform even today. Get rid of departmental policy that is not statuorily supported. Examples upper level reviews that are just because.

Of course the above changes would require revamp of a whole lot more. The CO certification system and adequate funding to support the acquisition workforce quickly come to mind. Others include an educated Congress that realizes the annual political manipulation of the aquisition statutes cause continual churn and chaos and a judicial system who grasps the change when conflicts arise. To the latter my example may be too simplistic but how the courts maniputlated termination for cause to look like termination for default.