FedSubK Feature: The Acquisition Lifecycle of Service Contracts - Phase 1 Acquisition Planning
Updated: May 4, 2024
This month we start a three-part series explaining why it is important for service contractors to understand the Federal acquisition lifecycle. Familiarizing yourself with the path you’ll walk to find, respond to, and possibly win Federal contracts is strategic. Two major advantages to businesses when they understand the lifecycle are:
● Strengthening Government Relationships. The ability to have meaningful conversations with the Government about your targeted contract actions and understand exactly where an action is in its lifecycle and the flow shows you appreciate the process and the work that goes into it from both the Government and industry perspective.
● Going In With Your Eyes Wide Open. Knowing the unique aspects of each phase in the lifecycle and its activities and sub-activities helps understand what the Government is doing and why at each phase. It pulls the curtain back and exposes the inner workings giving you the ability to be proactive, manage time and resources, and develop strategies to mitigate business risks during the process.
The lifecycle of a typical Federal services contract valued over the SAT involves three phases and many steps. The basic acquisition lifecycle for all contract actions is depicted below.
While the Government has several guides outlining either a 7-Step Process or 8-Step Process for Performance-Based Service Acquisitions (PBSAs), they focus heavily on the steps performed by the Government leading up to the solicitation of the requirement and not enough on the specific steps in the process wherein the offeror/contractor becomes involved after submission of an offer and contract execution. For that reason, our discussion will delineate those same processes using the three phases named above for clarity.
Acquisition Planning (Pre-Solicitation)
This phase is performed entirely by the Government before the issuance of the solicitation and includes input from industry as a result of market research efforts from the Government. Tasks in this phase include deciding--
● the Government’s need through market research, development of the acquisition strategy and/or acquisition plan, preparation of a random order of magnitude (ROM) or detailed Independent Government Cost Estimate (IGCE), and budget commitment.
● the Government’s requirements, including preparation of the statement of work (SOW), performance work statement (PWS), or statement of objectives (SOO).
● the extent of competition based on available competition pools and consideration of the use of set-asides to one or more of the Federal contracting assistance programs managed by SBA.
● the factors, criteria, and method of procurement to be used in the source selection process.
● the provisions and clauses for selection and use in the solicitation.
Steps in the Acquisition Planning (Pre-Solicitation) Phase
Legend: I = Integrated Project Team, P = Project Management Office / Requestor, and A = Acquisition Office
The steps, while depicted linearly, may be performed in tandem with those involved in the various steps of the pre-award phase. In the end, these tasks will culminate in an approved acquisition strategy and solicitation document to be published on SAM.gov.
Let’s discuss some specific elements of the Acquisition Planning phase for further understanding.
Market Research (FAR Part 10)
Market research is performed by the Government to “...arrive at the most suitable approach to acquiring, distributing, and supporting supplies and services.” Market research is always used, regardless of dollar value, but the extent of market research varies. Factors such as urgency, estimated dollar value, complexity, and the Government’s past experience making the same/siimilar purchases are taken into consideration.
A variety of market research techniques are available and may be used by the Government, taking into account the factors above and agency regulations and policy. They are:
● Contacting knowledgeable individuals in Government and industry regarding market capabilities to meet requirements.
● Reviewing the results of recent market research undertaken to meet similar or identical requirements.
● Publishing formal requests for information in appropriate technical or scientific journals or business publications.
● Querying the Governmentwide database of contracts and other procurement instruments intended for use by multiple agencies available at https://www.contractdirectory.gov/contractdirectory/ and other Government and commercial databases that provide information relevant to agency acquisitions.
● Participating in interactive, online communication among industry, acquisition personnel, and customers.
● Obtaining source lists of similar items from other contracting activities or agencies, trade associations or other sources.
● Reviewing catalogs and other generally available product literature published by manufacturers, distributors, and dealers or available online.
● Conducting interchange meetings or holding pre-solicitation conferences to involve potential offerors early in the acquisition process.
● Reviewing systems such as the System for Award Management (SAM.gov), the Federal Procurement Data System (FPDS), and the Small Business Administration's (SBA's) Dynamic Small Business Search (DSBS).
The Contracting Officer is allowed to use market research that is conducted within 18 months of an award for orders if the information is still current, accurate, and relevant. However, with large complex acquisitions that are recurring in nature (i.e., Governmentwide Acquisition Contracts (GWACs), Best in Class (BIC) contracts) it is not unheard of for market research to start anywhere from 24 to 30 months forward before the planned award date of a contract.
Acquisition Plan (FAR Subpart 7.105)
Aside from the statement of need, the contents of a written acquisition plan are lengthy at best. As someone who has written my fair share of acquisition plans and been the approving official on others, the list below shows the detailed considerations made by the Government when a written acquisition is required by the agency:
● Requirements for compatibility with existing or future systems or programs.
● Known cost, schedule, and capability or performance constraints.
● Life-cycle cost and how they will be considered, to include the cost model used.
● Design-to-cost objectives and underlying assumptions to include economic adjustment factors.
● Application of should-costs analysis to the acquisition.
● Required capability or performance characteristics.
● Basis for delivery or performance-period requirements.
● Trade-offs among the various cost, capability or performance, and schedule goals.
● Technical, cost, and schedule risks and efforts to reduce risk as well as the consequences of failure to achieve goals.
● Acquisition streamlining plans and procedures.
● Summary of prospective sources of supplies or services to meet the need to include:
○ Required sources of supplies and services (FAR Part 8).
○ SBA Federal Contracting Programs and use of set-asides.
○ Consolidation and bundling and how it may affect participation of small businesses.
○ Market research results.
● Competition requirements in terms of how it will be sought, promoted, and sustained through the acquisition lifecycle.
● Rationale for the contract type selected.
● Source selection procedures to be utilized.
● Acquisition considerations like multi-year contracting, multiple-award contracting, use of orders and/or options, other special contracting methods under FAR Part 17 to be used, special clauses or solicitation provisions, deviations, use of negotiated procurements, and/or lease or purchase of equipment.
● For Information Technology acquisitions:
○ Capital planning and investment control requirements.
○ Internet Protocol (IP) compliance requirements.
○ Accessibility standards.
● Budget estimates and funding sources.
● Product and service descriptions.
● Priorities, allocations, and allotments rationales for urgent requirements with a short delivery or performance schedule.
● Consideration of Office of Management and Budget (OMB) Circular No. A-76 regarding contractor versus Government performance of the work.
● Determination that the work is not inherently governmental (i.e., must be performed by a Government employee due to the nature of the duties performed or work requirements).
● Management systems that will be used to monitor the contractor’s effort, including Earned Value Management Systems (EVMSs) and the methodology to be employed to analyze and use the data to assess contractor performance.
● Make or buy decisions.
● Test and evaluation programs to be employed.
● Logistics considerations.
● Indication of any Government-furnished property to be used during performance.
● Environmental and energy conservation objectives and the applicability of any environmental assessment (EA) or environmental impact statement (EIS) on performance.
● Security considerations to include dealing with classified information, cybersecurity, physical security, and control of data to include Privacy Act Data.
● Contract administration procedures to be used including inspection and acceptance, enforcement of performance criteria, quality assurance, and identification of critical items.
● Other considerations, as applicable, such as:
○ Standardization concepts.
○ Industrial Readiness Program.
○ The Defense Production Act.
○ The Occupational Safety and Health Act.
○ The Support Anti-terrorism by Fostering Effective Technologies (SAFETY) Act of 2002.
○ Foreign sales implications.
○ Special considerations for contracts performed in a designated operational area or supporting a diplomatic or consular mission.
● Additional information related to major systems development or production contracts.
● Milestone schedule for the acquisition cycle.
● Identification of participants in the preparation of the acquisition plan.
FAR Subpart 37.102(a) dictates that performance-based acquisitions are the preferred method for acquiring services (Pub.L. 106-398, section 821) and must be used to the maximum extent practicable except for architect-engineer services, construction, utility services, and services that are incidental to supply purchases.
Did you realize that the Requiring Activity and Contracting Officer documented all those considerations? The Acquisition Plan is the “go-to” document when questions come up later in the acquisition process. I can’t tell you how many times as a Contracting Officer I had to remind the team when someone would get an idea to evaluate some new factor or change the competition pool – “What does the Acq Plan say?”
Competition Requirements
With certain limited exceptions, Contracting Officers are to promote and provide for full and open competition in soliciting offers and awarding Government contracts. Those exceptions include:
● Establishing or Maintaining Alternative Sources
Agencies may exclude a particular source because doing so would increase or maintain competition and likely result in a reduced overall cost for the acquisition, be in the interest of national defense, ensure the continuous availability of a reliable source of supplies or services, satisfy projected needs based on a history of high demand or satisfy a critical need for medical, safety, or emergency supplies.
● SBA Federal Contracting Assistance Programs
To fulfill the statutory requirements related to small business, 8(a), HUBZone, SDVOSB, WOSB, or EDWOSB concerns, contracting officers may set aside solicitations to allow only those businesses to compete with no separate justification needed to do so.
● Other Than Full and Open Competition
The Government may also use other statutory authorities to support other than full and open competition. The Department of Defense, Coast Guard, and National Aeronautics and Space Administration are subject to 10 U.S.C. 3204. Other executive agencies are subject to 41 U.S.C.3304. Contracting without providing for full and open competition or full and open competition after exclusion of sources is a violation of statute unless allowed by one of the exceptions below.
○ Only one responsible source and no other supplies or services will satisfy agency requirements. (FAR Subpart 6.302-1)
○ Unusual or compelling urgency. (FAR Subpart 6.302-2)
○ Industrial mobilization; engineering, developmental, or research capability; or expert services. (FAR Subpart 6.302-3)
○ International agreement (FAR Subpart 6.302-4)
○ Authorized or required by statute (FAR Subpart 6.302-5)
○ National security (FAR Subpart 6.302-6)
○ Public interest (FAR Subpart 6.302-7)
Solicitation Terms and Conditions
Solicitation terms and conditions are prescribed by the FAR and agency FAR supplements (see FedSubK Feature - Agency Supplements: The FAR and Its Child Regulations for more info on FAR supplements). A tip for understanding why a clause is included in a solicitation or contract is to read the prescription and any cross-reference material the prescription points to in the FAR.
The prescription for each provision or clause is found in FAR Part 52.2 and stated before each clause. For example:
Clicking on the hyperlink for the prescription will take you to the FAR subpart that explains the applicability of the clause and likely references to further information related to the clause and compliance.
Terms and conditions-like statements may also be found in the Statement of Work (SOW), Performance Work Statement (PWS), or Statement of Objectives (SOO) about site security, safety, badging, facilities access, and more. Be sure to understand those requirements as well as the compliance and reporting requirements of FAR provisions and clauses.
Under the Christian doctrine, a mandatory government contract clause that was not included in a government contract may be assumed included in the contract by operation of law, even when the clause is not written into or referenced by the contract. For example, under the Christian Doctrine, if the Buy American Act clause was inadvertently left out of a construction contract, the Act still applies to the Federal contract.
Summary
There’s a lot involved in the acquisition planning for a solicitation. Sometimes these steps take years to many months for major systems and highly complex acquisitions. For smaller or routine purchases, they can be accomplished in a matter of 45-90 days. But each new contract for services follows the same general Acquisition Planning (Pre-Solicitation) path.
The next time you talk to the Government about an upcoming acquisition, you can ask about where in the process the action is and know the path ahead. Next month we will talk about the next phase of the acquisition lifecycle; Contract Formation & Source Selection (Award).
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FedSubK Feature: Be Seen! Why Your SBS Profile is So Important
UPDATED November 2025 to incorporate changes from the SBA Dynamic Small Business Search (DSBS) to the new SBA Small Business Search (SBS)
I’ve posted on LinkedIn a lot recently about ways to be seen as a little fish in the big pond that is the Federal marketplace. Every GovCon consultant has a take on the best entry points with agencies. My take is there is only one place small businesses MUST put their best foot forward to be quickly and easily seen by Federal buyers for potential opportunities and influence small business set-asides.
The Small Business Administration (SBA) Small Business Search (SBS) is THE PLACE you must be on your A-game.
The Small Business Search (SBS) is a database in which SBA houses information on the current pool of certificated small businesses. Presently, small businesses that do not have certifications or are self-certified, may also create a profile in this database. The SBS is used by contracting officers, small business specialists, large prime contractors, and other small businesses looking for teaming partners to find small businesses that can help meet Federal requirements and identify businesses that can help the Government (or a prime contractor) meet its small business goals. SBS is one of the first--and often only--sources used in market research by agencies to determine the numbers of small businesses able to provide products or services by North American Industry Classification System (NAICS) code.
You can see why this might be an important place to pay attention to, eh?
Businesses have forgotten about the SBS in the last few years because SAM.gov no longer sends small business registrants directly to SBS at the end of their registration to complete the profile like it used to. I HUGE bummer. Businesses now must wait for their SAM.gov registration to be activated, then they can establish an SBA SBS account, claim their entity record, and fill in their company profile in the SBS system. Federal buyers are looking for detailed information from SBS to use as part of their market research efforts.
SBS isn’t only for market research.
Even more importantly, the SBS shows Federal buyers the status of any pending certification applications for the purpose of determining whether you are eligible to compete for a set-aside action. For example, an Economically Disadvantaged Woman Owned Small Business (EDWOSB) can still submit an offer for an WOSB set-aside even with a pending application for certification showing in the SBS. Contracting Officers often use SBS as a source to confirm the socioeconomic certification status and 8(a) program participation along with SAM.gov.
While MySBA Certifications automatically sends socioeconomic certification status to SAM.gov and updates the requisite reps and certs to reflect the correct socioeconomic status, recently it has taken weeks for that migration to occur. WOSBs and EDWOSBs have reported not seeing their correct socioeconomic status reflected in their SAM entity record.
Businesses should always check their SAM entity record to ensure that the proper status is shown within a reasonable time after receipt of an active certification status; usually within 14 business days. If the record is not accurately reflected, you can contact answerdesk@sba.gov or the SBA socioeconomic program under which your business was certified for assistance. If a Contracting Officer says that your SAM record does not reflect the status claimed, ask the Contracting Officer to check SBS for the more accurate information because of these delays.
So now let’s talk about BEING SEEN in SBS and walk through each part of the registration.
Understanding how to maximize the fields in SBS is how you can make the best possible first impression so that Federal buyers want to learn more about YOU!
The Key Words
Often businesses pluck these from thin air and over-generalized based on what they think the Government wants to see. Key words need to reflect and incorporate aspects of your primary NAICS, secondary NAICS, and what you can provide under those NAICS. If you use key words that don’t reflect your primary NAICS, you’ll leave the Government scratching their head about you. They won’t understand the message you’re sending about your company. Be consistent and specific with key words while tying into your NAICS codes in order to leave the best impression. You have 500 characters -- use them wisely.
The Website
Be sure that you include the URL for any website you have. Make it be more than a landing page. It needs to tell your story. It needs to include information about your company, what you sell, past customers, and products or solutions you provide. And most of all, it must be polished. Scrub your site hard for formatting, typos, grammatical errors, etc. Acquisition personnel using the SBS will often quickly click on the site to see just how polished it is. When it looks good, they get the impression you know your stuff and pay attention to details.
The Capabilities Narrative
This is the written equivalent of your elevator pitch. This section should include all the things you’d include in that two-minute speech. Hit hard on what your company specialized in and its core product or service areas. Show the business’s focus and avoid being all over the map by overpromising on the breadth of work the business performs.
Near the end of the capabilities narrative, list any socioeconomic certifications Why not lead with it? Because that certification is only part of your business, and it alone does not get you interest from the Contracting Officer. End with that information so the Contracting Officer can easily see it in a quick query and get your business into their market research counts.
Lastly, identify any government contract vehicle or GSA Schedule your company may hold. If you can catch their eye that you have an existing GSA Schedule or your business participates in the 8(a) program, you’ll get counted and likely get a look in terms of the Contracting Officer wanting to know more. If they need to meet a socioeconomic goal, they can see quickly. You’re helping the Contracting Officer do their job. They LOVE that! (And made another great first impression!)
SBS now also includes a field to add a link to your online capabilities statement. Use it!
“Extras” You Should Never Skip
Performance History
I cannot say this enough…if you history doing work for any Government or quasi-Government entity at any level -- Federal, State, or Local level -- list them! Don’t play the “they’ll see that when I propose” game. Showing performance history—even if it is minimal or commercial and not Government--helps. How? It proves the viability of the business and the size and types of projects you’ve completed. Those goes a long way to determining eligibility of the business based on performance on same / similar work of a same / similar dollar value (“Rule of Two” stuff – you can read more about that here).
Review Your Profile
Go out to the SBS site and use the filters for your NAICS, business name, geographic location, and business types. Make sure your show up and see how your profile measures up to your competitors. Look at their records and see what they included that you haven’t. Use the good ideas of others, but don’t plagiarize. Contracting Officers will see that and that won’t look good for either of you.
Keep Evolving
Your SBS isn’t something that you can just set and forget either. Make reviewing your profile in SBS something you do when you renew your SAM.gov registration every year. If something major changes in your business focus, NAICS, or socioeconomic status, make associated changes in SBS.
What GovCon doesn't always talk about -- The SBS Influence
When doing market research and trying to determine if an acquisition should be set-aside for small businesses, the Government is not only counting about the numbers of small businesses that claim they can do the work under a NAICS code in SBS. They are analyzing your SBS profile to see if your business could be one of the "... two or more responsible small business concerns that are competitive in terms of fair market prices, quality, and delivery" and they have “…a reasonable expectation of obtaining an offer…” from you. (There’s that pesky “Rule of Two” again.)
In other words, based on what they see, could you submit a proposal likely to win? And how does a Contracting Officer determine that? Simply put... the your answers to everything we just covered.
Completing your profile helps tip the market research scales toward a small businesses set-aside and possibly a specific socioeconomic set-aside. If you're all over the map in your SBS narrative, the Government will not consider you viable eligible contractor towards that “Rule of Two” and could possible choose to go another way with their acquisition strategy, away from a small business set-aside. Or worse, they set it aside but remember your name from the market research as one of the businesses that didn’t make their initial market analysis cut.
Influence where you can! SBS is the place where you have a lot of influence!
Have I convinced you to get out there and create or update your SBS profile yet?
While the system is no longer got the word "Dynamic" in the title, don't forget its meaning. Life is dynamic, business is dynamic, and your SBS profile should still be dynamic, too. Get it completed ASAP. You can’t afford not to.
Remember again, SBS IS WHERE FEDERAL BUYERS GO TO FIND SMALL BUSINESSES and where other small businesses go to find teaming partners and subcontractors.
Get out there, GET NOTICED, BE SEEN, and STAY DYNAMIC!
(former title: FedSubK Feature: Be A Dynamic Small Business!)
Ask for the Meet and Greet. Make the Phone Calls.
I sat in on a session yesterday where another GovCon was talking about watching SAM for opportunities. But if you are doing that, you are going to be too late, unfortunately. Small businesses must start ahead of any opportunity announcement and connect with agency personnel early, before the opportunity is announced in order to be known and help shape future acquisition strategies. It got me thinking about my days as a Branch Chief and Chief of Contracting and the small businesses I know that are still flourishing today.
One particular company stands out. They were a new 8(a) firm that asked for a meet and greet. They had no federal work but showed a level of understanding about our mission that made an impression. While our acquisition strategies were in place already for the end of FY run of award, I told them I'd keep them in mind new projects crossed my desk. Every month, without fail, I would get a call or a quick drop in chat from this 8(a) to say hello and briefly inquiry about any possible upcoming projects. During one of the in-person chats about a year after our first meeting, our chief estimator popped his head in my office quickly to apologize for a few late government estimates. He said he was going crazy with end of FY and lack of staff. The 8(a) took the opportunity and said, "We can help with that." While it wasn't ideally the work the 8(a) was looking for, that simple pivot and flexibility, along with the relationship building done to that point, led to a small 8(a) sole source contract for cost estimating support. It was their first federal contract. That small contract quickly turned into a much larger 8(a) sole source contract for the same work that reached its max capacity 18 months earlier than anticipated. That led to 8(a) contracts for environmental the work the company ideally wanted, then graduation from the 8(a) program, and successfully competing on SB set-asides throughout the region and getting their own (successful) GSA Multiple Award Schedule contract.
Ask for the meet and greet. Make the phone calls. This former CO is here to tell you that acquisition personnel and SB Specialists EXPECT to hear from businesses. Large businesses aren't shy about calling (trust me). They may not be able to tell you much, but the relationship building and continual reminder that you know what they are looking for and can fill a niche--even when it's not your first choice of work--is KEY.
Small businesses must start ahead of any opportunity announcement and connect with agency personnel early, before the opportunity is announced in order to be known and help shape future acquisition strategies.
FedSubK Feature: What is Buying In?
"Buying in". Do you know what that is? Let's illustrate it with a little story...
Once upon a time an agency leader🤴 was looking around at things to make 🌟efficient.🌟 They got the idea that every agency should have the same widgets🔅 their agency had.
The agency leader🤴 called up a widget company👩🔧 and said, "We are interested in your widgets. 🔅What kind of discount can you give us?"
The widget company👩🔧 offers a discount 📉 because they know this agency🤴 not only buys for themselves but may buy for other agencies🫅🤴👸 where a highly trusted widget competitor👨🔧 presently has the work.
The widget company👩🔧 was "buying in" -- offering unrealistic discounts📉 that made the price unrealistically low not only for the current effort but also to influence the purchasing decisions on future buys. Then prices usually up 📈 again over time.
Depending on when "buying in" happens there could also be questions related to compliance with the Competition in Contracting Act (CICA) and possible other violations.
This is why agency announcements that management has made a deal for "$1 a license" and other such management interference is of concern. 🚨 Management plays the numbers game. I'm not saying numbers aren't important, but let's just say... there is a real reason why management typically does not hold contract signature authority. 😬😉
The Government is supposed to keep things fair and do its due diligence. But it's falling for the oldest trick in the book.
Risk, intent, compliance with statutory requirements, misunderstanding of requirements, and comparable market pricing must be evaluated when the Contracting Officer has reason to believe a proposed price is unrealistically low price. But are they?
If a contract isn't in place, there there is still a need to follow appropriate competition rules before a handshake deal. If a contract is already in place, there are things to consider when new discounts appear to be unrealistic including the risk of continued performance, depending on the type of product or service being purchased.
The Government gets a quick win to lock in a low rate, saving some money now. That's called the short game. Government buyers getting blurry-eyed over unbelieveably low prices and don't do the long-term analysis.
But I'll bet you a dollar the company is playing the long game. They are watching and waiting, getting to know your needs and asking loads of questions. "When do you use my widget most?" "Who buys the most widgets?" "When do you typically buy widgets?" And then as fast as they dropped the price, they raise it again on you when you can't afford to make a change -- like at an end of fiscal year. That's how they get locked in and receive perpetual contracts.
BTW...the fairy tale above is a true story. I've had new politicals and new leadership / commanders trot companies into my office saying "Company ABC here says they want to sell us "widgets" at a huge discount compared to what we're paying or others are paying now."
Well...okay then.
As a Contracting Officer, whether I could even begin to entertain that idea depends on several things. It's not an automatic "yes". You could replace "widgets" with just about any product or service and it's probably happened to a Contracting Officer somewhere. Especially as new Administrations come into Government.
The stories in the news that made me think -- "Huh, are they buying in?" are the Axios story "Anthropic wants to sell Claude to the Government for $1". (https://www.axios.com/pro/tech-policy/2025/08/05/ai-anthropic-government-sale-dollar) and FedScoop story "Federal agencies can buy ChatGPT for $1 through GSA deal" (https://fedscoop.com/openai-chatgpt-enterprise-federal-government-gsa-deal-general-services-administration-anthropic/).
My husband (also a retired Contracting Officer) and I look at each other often during the news now and, based on the reported discount or price alone, we know that company is likely "buying in". That's based on our combined 72 years of Fed experience and our Contracting Officer "Spidey sense" from having been around the block a few times. But these deals just the most recent in a series of deals GSA is making with companies since the new Administration came to town. OneGov is the program GSA is, in my former Contracting Officer opinion, using to tout savings under for the press releases. But it may come back later to be a big mistake. I hope I'm wrong.
Program/Project Managers and Contracting Officers AND the competition to these companies...LEARN about it and WATCH for it. It's on the rise.
(And don't get me started on having to argue with new politicals, leadership, and commanders about why I can't terminate a current contract and then turn around and give the same work to another contractor at their unrealistic lower price.🙄😱 That's a topic for another time.)
The practice of "buying in" is becoming more common now. Learn about it and how to spot it.
