When you order from GSA Federal Supply Schedules, you normally need to give multiple schedule holders a fair shot. FAR 8.405-6 tells you when and how you can limit that competition.
The three circumstances, what to document, and who needs to approve.
FAR Part 6 covers competition on the open market. FAR Part 8 covers ordering from existing Federal Supply Schedules. They are separate authorities with separate rules. When you place an order against a GSA schedule, you do not need a Part 6 J&A. You follow Part 8 procedures instead. Part 8.405-6 specifically addresses when you can limit the number of schedule contractors you solicit, or restrict an order to one source on a schedule.
Each FAR Part has its own lane for restricting competition, and each lane has its own name for the sole source document:
FAR Part 6: Justification and Approval (J&A). Non-commercial, open market procurements above the SAT.
FAR Part 8: Limited Sources Justification. Orders from Federal Supply Schedules (GSA).
FAR Part 12: Commercial Sole Source Justification. Commercial item buys using simplified procedures.
FAR Part 16: Exception to Fair Opportunity. Task and delivery orders off IDIQ and requirements contracts.
When someone says "limited sources justification," a sharp contracting officer hears "GSA schedule order."
FAR 8.405-6 allows you to limit sources in three situations:
1. An urgent and compelling need exists, and following the normal ordering procedures would result in unacceptable delays. This is the schedule equivalent of urgency. The need must be genuine and unforeseen, not just poor planning.
2. Only one source is capable of providing the supplies or services at the level of quality required because the supplies or services are unique or highly specialized. The key word here is "capable." If only one vendor on the schedule can actually meet your specific technical requirements, you can go directly to them.
3. The order is a logical follow-on to an order already issued under the schedule. If you have an existing order and it makes sense to continue with the same vendor for continuity, you can limit the follow-on. However, you need to justify why switching vendors would be disruptive or costly.
The documentation burden depends on the dollar value of the order.
Orders above the micro-purchase threshold but at or below the SAT: The contracting officer documents the basis for limiting sources in the contract file. Include which of the three circumstances applies, what market research you conducted among schedule holders, and a determination that the order represents the best value. If using the logical follow-on basis, describe why the relationship between the original order and the follow-on is logical.
Orders above the SAT: You need a formal written justification that includes the eleven elements listed in FAR 8.405-6. These cover identification of the contracting activity, description of the requirement with estimated value, the basis for limiting sources with supporting rationale, a best value determination, market research results, and certifications.
FAR 8.405-6 sets the approval levels based on the estimated value of the order:
Above the SAT but not above $900,000: The ordering activity contracting officer's certification serves as approval, unless a higher level is established by agency procedures.
Above $900,000 but not above $20M: The advocate for competition of the ordering activity. This authority is not delegable.
Above $20M but not above $90M ($150M for DoD, NASA, Coast Guard): The head of the procuring activity, or a designee who is a general/flag officer or civilian serving above GS-15.
Above $90M ($150M for DoD, NASA, Coast Guard): The senior procurement executive. Not delegable, except for the Under Secretary of Defense for Acquisition and Sustainment.
Agencies may delegate the lower thresholds differently. Check your local policy for specific delegation guidance at your activity.
For orders exceeding the SAT, the contracting officer must post the justification within 14 days of placing the order. The justification goes on SAM.gov and the agency website for a minimum of 30 days. For urgent/compelling need orders, you can proceed with the order and post within 30 days after award instead.
Before posting, screen the justification for contractor proprietary data and remove it. If the justification appears to contain proprietary information, give the contractor a chance to review it before posting, but do not let that process delay the posting timeline.
For orders valued above the SAT, FAR 8.405-6 requires a written justification that includes, at minimum, the following eleven elements:
(1) Identification of the agency and contracting activity, and specific identification of the document as a "Limited-Sources Justification."
(2) Nature and/or description of the action being approved.
(3) A description of the supplies or services required to meet the agency's needs, including the estimated value.
(4) The authority and supporting rationale, including a demonstration of the proposed contractor's unique qualifications or the nature of the acquisition that requires limiting sources.
(5) A determination by the ordering activity contracting officer that the order represents the best value consistent with FAR 8.404(d).
(6) A description of the market research conducted among schedule holders, or an explanation of why market research was not conducted.
(7) Any other facts supporting the justification.
(8) A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services.
(9) The contracting officer's certification that the justification is accurate and complete to the best of the contracting officer's knowledge and belief.
(10) Evidence that any supporting data from technical or requirements personnel has been certified as complete and accurate by those personnel.
(11) A written determination by the approving official that one of the circumstances for limiting sources applies.
Element (4) is the heart of the document. Element (5) is what makes Part 8 different from the others: you must affirmatively determine best value, not just fair and reasonable pricing. Element (6) is where you show your work among the schedule holders specifically.
Check the LSJ Examples tab to see how this looks on paper, and how it falls apart when done wrong.
Same scenario, two very different justifications. A base Communications Squadron needs to order a SIEM/SOAR cybersecurity platform through GSA MAS. The order is above the SAT, so the full 11-element justification under FAR 8.405-6 applies. Click highlighted sections for coaching notes. Blue borders = strong. Red borders = problems.
Limiting Sources. The complete regulatory text for restricting competition on Federal Supply Schedule orders.
Read on acquisition.govOrdering Procedures for Supplies, and Services Not Requiring a Statement of Work. The baseline ordering procedures that 8.405-6 creates exceptions to.
Read on acquisition.govOrdering Procedures for Services Requiring a Statement of Work. Service ordering procedures and when limiting sources interacts with the SOW process.
Read on acquisition.govThe online Request for Quote (RFQ) tool for GSA Schedule orders. Where you post schedule solicitations.
Visit GSA eBuy