Limiting sources
Limiting sources under Federal Supply Schedules requires strict justification, documentation, and public posting to ensure transparency and compliance with competition policies.
Overview
FAR 8.405-6 outlines the requirements and procedures for limiting sources when placing orders or establishing Blanket Purchase Agreements (BPAs) under Federal Supply Schedules (FSS). While FSS orders are exempt from FAR Part 6 competition requirements, contracting officers must justify and document any restrictions on competition, especially when exceeding the micro-purchase threshold. The regulation details acceptable circumstances for limiting sources, such as urgent needs, unique capabilities, or logical follow-ons, and sets out specific documentation, posting, and approval requirements based on order value. It also addresses brand-name justifications, public posting obligations, and approval hierarchies for higher-value acquisitions, ensuring transparency and accountability in source-limited procurements.
Key Rules
- Justification for Limiting Sources
- Orders or BPAs exceeding the micro-purchase threshold must be justified if competition is restricted, with only certain circumstances (urgency, unique source, logical follow-on) permitted.
- Brand-Name Justifications
- Brand-name specifications are only allowed if essential and market research confirms no alternatives; documentation and posting requirements apply based on value thresholds.
- Documentation and Posting
- Justifications must be documented, approved, and posted publicly (e.g., on SAM.gov and eBuy) within specified timeframes, with exceptions for national security or impracticality.
- Approval Levels
- Approval authority for justifications escalates with order value, from the contracting officer to senior procurement executives for the highest-value actions.
Responsibilities
- Contracting Officers: Must prepare, screen, approve, and post justifications; ensure compliance with documentation and approval requirements; protect proprietary and sensitive information.
- Contractors: Should provide necessary information for justifications and review for proprietary data when requested.
- Agencies: Oversee compliance, ensure proper approvals, and assist in justification preparation.
Practical Implications
- This section ensures that limiting competition under FSS is justified, documented, and transparent, protecting government interests and promoting fair access. Contractors should be aware of justification requirements and posting obligations, as improper or incomplete documentation can delay awards or lead to protests. Common pitfalls include inadequate market research, missing approvals, or failure to redact proprietary data before posting.