Firms that learned federal contracting through large negotiated procurements sometimes approach GSA Schedule requests for quotations as if they were miniature requests for proposals. The two are related but governed by different rules. Schedule orders follow the procedures in FAR Subpart 8.4, and the FAR states that its negotiated procurement rules in Part 15 do not apply to orders and blanket purchase agreements under Federal Supply Schedules. Here are answers to common questions about what that means. This is general information, and the current FAR text controls.
If Part 15 does not apply, what rules do?
The ordering procedures in Subpart 8.4, plus the terms of the request for quotation itself. Those procedures scale with the size of the order and, for services that require a statement of work, call for the ordering activity to provide the statement of work and the evaluation criteria to schedule contractors, evaluate responses against those criteria and document the basis for its choice. That makes the RFQ the most important document in the competition: its instructions, evaluation factors and basis for award are what you must satisfy, and what the agency will be expected to follow.
Does the agency still evaluate price?
Yes, though differently. GSA has already determined that schedule prices and rates are fair and reasonable at the contract level, so ordering activities generally do not make a separate fair-and-reasonable determination for each order. For services, however, the ordering activity is responsible for considering the level of effort and the mix of labor proposed for the specific task and for determining that the total price is reasonable. A low hourly rate does not help if the hours or the labor mix look wrong for the work.
Will there be a competitive range, discussions or final revisions?
Not in the formal Part 15 sense. Schedule ordering procedures do not require a competitive range or Part 15 discussions, and many orders are placed on the basis of initial quotes. Agencies can ask questions and may seek revised quotes or price reductions, and some requests for quotations describe exchanges with vendors in detail. When an RFQ borrows Part 15 vocabulary, read it closely, because the agency may have committed itself to the process it described. Either way, treat your first quote as your best one.
What about debriefings and protests?
The formal Part 15 debriefing rules do not apply to schedule orders. For services orders requiring a statement of work, the FAR provides that when an award was based on factors other than price alone, an unsuccessful quoter that asks will receive a brief explanation of the basis for the award decision. Protests involving schedule orders can be brought, and protest forums generally ask whether the agency’s evaluation was reasonable and consistent with the RFQ and applicable procurement rules. Deadlines are short, so if you are considering a protest, talk to a government contracts attorney quickly.
- Read each RFQ for the evaluation approach it states, rather than assuming Part 15 procedures.
- Address the stated criteria directly and in order.
- For services, make the hours and labor mix clearly reasonable for the work described.
- Ask for the brief explanation when you lose an order evaluated on more than price.
The FAR’s schedule ordering procedures are in Subpart 8.4 at acquisition.gov.