GSA Orders above the SAT

If you completed the previous training on GSA orders under the SAT, you already know the basics: GSA schedules are pre-competed contracts, and GSAM 538.71 contains the ordering procedures. Everything you learned still applies — but above the SAT ($350,000), the rules tighten up.

The key differences at this level:

• Broader competition. You must solicit as many FSS contractors as practicable, not just three.
• Formal RFQ required. Your RFQ must describe the work and explain the basis for selection.
• Sole source justifications. If you can't compete, you need a written justification under GSAM 538.7104-3 — with public posting requirements.
• Documentation if fewer than three quotes. If you receive fewer than three quotations, you must document your efforts to find additional contractors.

For orders above the SAT, you have two competition methods. Unless you have a sole source justification under 538.7104-3(b), you must use one of these:

Option 1: Publish an RFQ on GSA eBuy. This is the most common approach for above-SAT orders. Posting on eBuy gives visibility to all schedule contractors in the relevant category.

Option 2: Issue an RFQ directly to as many FSS contractors as practicable. The goal is to reasonably ensure you receive quotations from at least three contractors. If you go this route and get fewer than three quotes, you must document what you did to try to find more.

In either case, your RFQ must describe the requirement and explain how you will select the awardee — the basis for award.

Your RFQ for an above-SAT GSA order needs two things the under-SAT version didn't require:

1. A description of the work. This can be a statement of work, statement of objectives, specifications, or a clear written description of what you're buying. The format doesn't matter as long as contractors understand what you need.

2. The basis for selection. Tell contractors how you'll pick the winner. This doesn't need to be a formal evaluation plan — remember, quotations are not offers and this is not a source selection. But you do need to state what matters to you: price, delivery, technical capability, past performance, or some combination.

Sometimes you can't compete an above-SAT GSA order. GSAM 538.7104-3(b) provides five statutory exceptions:

1. Unusual urgency — the need is so urgent that following standard competition procedures would cause unacceptable delay
2. Only one source — only one contractor can provide the required level of quality or service
3. Logical follow-on — the order is a logical follow-on to a prior competitive FSS order
4. Minimum guarantee — the order satisfies an FSS BPA minimum guarantee
5. Statutory requirement — a law requires a specific source

The justification must be in writing with sufficient detail and supporting rationale. It also has to be publicly posted within 14 days of award (30 days for urgency exceptions), after screening for FOIA-exempt information.

Once you receive quotations, evaluate them fairly against the basis for selection you stated in the RFQ. Award to the contractor representing best value.

After award, notify unsuccessful quoters. If any contractor requests it within 3 days, you must provide a brief explanation of the basis for the award decision. This isn't a formal debriefing — just a short explanation of why they didn't win.

Before award, check SAM.gov to confirm the contractor isn't excluded or debarred.

• Using the under-SAT procedures. Above the SAT, you can't just survey GSA Advantage and screenshot prices. You need an actual RFQ with a described basis for selection.
• Not posting on eBuy. eBuy is the easiest way to demonstrate broad competition for above-SAT orders. If you're issuing RFQs directly instead, make sure you're reaching as many contractors as practicable.
• Weak sole source justifications. "We've always used this contractor" or "they're the only one we know" won't hold up. The justification needs to address one of the five statutory exceptions with real supporting rationale.
• Forgetting to post the sole source justification. It must be publicly posted within 14 days of award. Missing this is a compliance failure.
• Not documenting fewer-than-three quotes. If you receive fewer than three quotations, you must document your efforts to identify additional qualified contractors. No documentation = audit finding.
• Overcomplicating the evaluation. You don't need scoring matrices or competitive ranges. State your basis for selection, evaluate fairly, pick the best value, and document your rationale.