GSA Orders above the SAT

Training

GSA Orders Exceeding the SAT

Above the SAT, GSA ordering gets more formal. GSAM 538.7103-3 requires broader competition, more structured RFQs, and written sole source justifications if you can't compete. Here's what changes.

1 What Changes 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.

          Still true above the SAT: Quotations are not offers. You don't need evaluation plans, scoring sheets, or competitive ranges. Award to the contractor representing best value based on the criteria in your RFQ.
        

2 Competition Requirements (GSAM 538.7103-3)

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.

          Practical tip: eBuy is usually the easier path for above-SAT orders. It broadcasts your RFQ to all applicable contractors so you don't have to manually identify and solicit them. It also gives you built-in documentation that the requirement was competed.
        

          No more GSA Advantage surveys. Unlike under-SAT orders where you can simply screenshot three prices on GSA Advantage, above-SAT orders require an actual RFQ with a described basis for selection. The survey-and-screenshot approach doesn't cut it here.
        

3 Writing the RFQ

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.

          Keep it proportional. A $400,000 order for clearly defined supplies doesn't need the same level of RFQ detail as a $2 million complex services requirement. Scale the RFQ to the complexity and risk of what you're buying.
        

4 Sole Source Justifications (GSAM 538.7104-3)

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

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

          This is a real justification. Don't treat this like a formality. If your justification doesn't hold up, you're exposed to a GAO protest. Make sure the rationale is specific and documented — not boilerplate.
        

5 Evaluation and Award

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.

          Remember: Even above the SAT, FSS quotation procedures are not source selections or negotiations. You evaluate and award — you don't establish competitive ranges or conduct discussions. Keep it straightforward.
        

6 Common Mistakes

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.

Walkthrough Scenario

Your organization needs a 12-month help desk support contract. The estimated cost is $500,000.

This exceeds the SAT ($350,000), so you need GSAM 538.7103-3 procedures. It's a services requirement, so you'll need a statement of work. Here's how:

Write a statement of work describing the help desk support — hours of operation, number of expected tickets, required response times, qualifications for support staff.
Draft an RFQ that includes the SOW and states your basis for selection (e.g., best value considering technical approach, staffing plan, past performance, and price).
Post the RFQ on GSA eBuy. This ensures broad visibility to all FSS contractors in the relevant category.
Evaluate quotations against your stated basis for selection. Check SAM.gov to confirm the apparent awardee isn't excluded.
Award to the contractor representing best value. Notify unsuccessful quoters.
Document your file: funding, requirement (SOW), RFQ, all quotations received, your evaluation and selection rationale, SAM.gov check, and the delivery/task order.

Submitting an RFQ on GSA eBuy

Above the SAT, GSAM 538.7103-3 and 538.7104 set the Fair Opportunity ordering procedures for every Schedule order. eBuy is the standard tool that satisfies that obligation. This walkthrough covers the screen-by-screen flow using a small-business set-aside for office furniture as the example.

          A note on citations. The Revolutionary FAR Overhaul (RFO) is consolidating FSS ordering procedures from FAR Subpart 8.4 into GSAM Subpart 538.71. The cites on this page reflect the current GSAM home for each procedure. Specific subsection numbers may continue to shift; cross-check the current text on acquisition.gov before relying on a specific cite in a written justification or solicitation.
        

1Before you log in

Three decisions to make on paper first:

Schedule and SIN. Which Multiple Award Schedule (MAS) Special Item Number does the work fall under? For our walkthrough example, MAS » Furniture & Furnishings » Office Furniture » SIN 33721 Office Furniture » subgroup Miscellaneous Office Furniture and Accessories. If you cannot pick a SIN, your market research is not done.
Set-aside or open competition. FAR 8.405-5 (still active under RFO consolidation) lets you set aside an order for a socio-economic category if there are at least two qualified vendors on the SIN. eBuy will let you filter the contractor pool by Small Business, 8(a), HUBZone, WOSB, EDWOSB, SDVOSB, VOSB. Decide before you start the request.
Attachments you will need. Salient characteristics or specifications. Pricing schedule (CLINs). And the offer-submission instructions / evaluation criteria document. Most COs use a single attachment that covers the latter two as the FAR Part 8 analogue to FAR 52.212-1 and 52.212-2. We provide a template at the bottom of this tab.

2Pick the request type

RFQ (Request for Quotation). Use this when you intend to award an order from the quotes received. This is the path for our walkthrough.
RFI (Request for Information). Use this for market research before issuing an RFQ. RFIs do not result in award.
RFP (Request for Proposal). Used when the order is large or complex enough that proposals (not quotes) are appropriate. Less common on schedule buys; FAR 15 procedures still do not apply, but the eBuy workflow accommodates a longer evaluation cycle.

Pick RFQ. Click Continue.

3Drill into the schedule

eBuy presents 12 large categories that mirror the MAS structure. Each one drills down into subcategories, then into MAS, then into specific SINs.

Pick the large category. For our example: Furniture & Furnishings.
Pick the subcategory: Office Furniture.
Pick MAS (Multiple Award Schedule).
Pick the SIN: 33721 Office Furniture. eBuy shows you a one-line description of what the SIN covers; if you are not sure your requirement fits the SIN, this is the moment to back up to market research.

At this point eBuy knows the universe of contractors on the SIN. It will now ask you to filter that universe.

4Filter the contractor pool

Two filters on the Select Contractors screen. Both shape who actually sees your RFQ.

Socio-Economic Designation. Each entry shows how many contractors on the SIN hold that designation. If you set aside under FAR 8.405-5, pick the appropriate box. For our example we pick Small Business, which on this SIN shows 185 holders. Two-or-more rule is satisfied; the set-aside is appropriate.

Subgroups. Many SINs are sliced into subgroups that further specialize the contractor pool. SIN 33721 has six: Casegoods, Desks and Systems Furniture, Filing and Storage, Miscellaneous Office Furniture and Accessories, Seating, Tables and Collaborative Furniture. Pick the subgroup that matches what you are buying. For our walkthrough, Miscellaneous Office Furniture and Accessories.

Tip. Counts shrink as you stack filters. If your filtered pool drops below two contractors, you have a sole-source decision in front of you, not a competition. Either widen the filter (different SIN, broader subgroup) or write the limited-sources justification under GSAM 538.7104-3 (see the FAR Part 8 limiting-sources training).

5Complementary SINs (the question that confuses most COs)

Before eBuy lets you write the RFQ body, it asks: "Would you like to allow contractors to offer supplies and/or services under one or more of the following Complementary SINs?" with options for Ancillary and OLM. Both are real, and both are useful. Quick translation:

          Ancillary SIN. Lets a contractor include incidental services or supplies that complement the primary work but are not on the main SIN. For our furniture buy: installation, removal of existing furniture, in-place furniture protection, delivery beyond standard inside-delivery terms. Without the Ancillary SIN added to the RFQ, a contractor whose primary award is Office Furniture but who also wants to bid the installation labor cannot include it cleanly. The Ancillary SIN is what tells the contractor "yes, you may quote installation as part of this order."
        

          OLM SIN (Order-Level Materials). Authorized under FAR 8.403(b). Lets a contractor include items that are not awarded on their MAS contract but are needed for the specific order. Capped at $250,000 per task or delivery order under the OLM rule. For our furniture buy, OLM might cover specialized hardware, custom finishes, or transit-protection materials that are not pre-priced on the contractor's MAS. The CO documents price reasonableness on OLM at order award; the underlying schedule pricing analysis does not cover OLM items.
        

Both are off by default. eBuy adding them does not expand or shrink your pool of contractors who see the RFQ. It just puts the contractor on notice that they may include those categories of items in their quote. For our walkthrough, we pick YES on Ancillary (we want installation quoted) and NO on OLM (the requirement is straightforward enough that we do not anticipate off-schedule materials).

          Trap. If you forget to enable Ancillary and your requirement actually needs installation services, contractors will either (a) leave installation out and the customer will have a half-finished delivery, or (b) include installation anyway with a footnote that may not be enforceable. Add Ancillary at the eBuy stage when you know installation is in scope.
        

6Request Info: the meat of the RFQ

eBuy presents a structured form. Fill it in the order it asks:

Request Title. Plain language. e.g., "Squadron Conference and Break Room Furniture Refresh."
Reference # / uPIID. Optional internal reference; helps your office track the action.
Follow-on Requirement. Check this box if the order follows a previous task order. eBuy will ask for the prior PIID. Useful for FPDS tracking and CPARS lineage.
Previous RFI Information. Check this box if you posted an RFI on this requirement before issuing the RFQ. Attach the RFI if relevant.
Description. Detailed description of what you are buying and any evaluation criteria. eBuy will append a boilerplate "this is a set-aside" sentence automatically when a set-aside filter is selected. Your description should reference the attached salient characteristics and the attached instructions / evaluation criteria document.
Contract Type. Select firm-fixed-price for a furniture buy. Other types include time-and-materials, labor-hour, or hybrid. Most schedule buys are FFP.
Commercial / Non-Commercial. For MAS or VA Schedule buys, Commercial is mandatory. For MAC and GWAC orders, cost-type contracts are Non-Commercial.
Close Date and Time. Eastern time. Default is 5 calendar days; minimum is 2. Once the RFQ is submitted you cannot pull the close date earlier. Avoid weekends and federal holidays.
Award Method. LPTA or best-value tradeoff. Match this to what your evaluation criteria document says. (Mismatched eBuy field and attached criteria invites protest grounds.)
Ordering Contracting Officer / Specialist. Name, title, agency, phone, AAC code. Both fields if you have both.

7Delivery, attachments, and line items

Delivery. Pick one: a number of days After Receipt of Order (ARO) for supplies, or a date-of-award-to-date-of-completion or specific period of performance for services. Furniture with installation typically uses ARO for delivery and a completion date for installation; document both in the attached SOW.

Attach Documents. This is where the Section L / Section M analogue lives. The minimum useful attachment set on a competed schedule buy:

Attachment 1: Instructions to Quoters and Evaluation Criteria. The FAR Part 8 equivalent of FAR 52.212-1 and 52.212-2. We provide a template at the bottom of this tab.
Attachment 2: Salient Characteristics or Specifications. What the items must do or contain to be acceptable.
Attachment 3: Pricing Schedule. Optional if you are using eBuy line items directly; needed if your CLIN structure is more complex than eBuy's interface allows.

Line Items. Optional in eBuy because the same information can live in your pricing-schedule attachment. Use the eBuy line-item function for simple, small-CLIN-count buys. For a complex pricing schedule, attach an Excel and skip the line-item entry.

Shipping Address or Place of Performance. Required. Use the actual delivery address; it appears in the contractor's order for routing.

8Submit and monitor

Submit. eBuy distributes the RFQ to the filtered contractor pool. Quoters submit through eBuy. The CO monitors via My Requests, can issue amendments (which require quoter acknowledgment), and can answer questions through the eBuy Q&A function. After close, eBuy locks the quotes and the CO downloads them for evaluation.

Evaluation, award, and order issuance happen outside eBuy: the CO documents the technical-acceptability determination, price-reasonableness analysis, and best-value or LPTA selection in the contract file, and issues the order through the agency's contract writing system.

9The template

Most COs writing their first eBuy RFQ pause at the Attach Documents step because there is no equivalent of FAR 52.212-1 / 52.212-2 to drop in. The download below is a starting point. It is built around a sample scenario (squadron conference and break room furniture refresh, small business set-aside, LPTA basis). Replace every bracketed field, swap in your salient characteristics, and you have an Attachment 1 ready to upload.

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eBuy RFQ Instructions and Evaluation Criteria Template

FAR Part 8 analogue to FAR 52.212-1 and 52.212-2. Submission method, format, required content, validity period, late-quote rules, technical-acceptability factor, price-reasonableness method under FAR 8.404, past performance, tiebreaker, reserved rights. Sample scenario included for reference.

↓ Download (DOCX)

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eBuy RFQ Salient Characteristics Template (Attachment 2)

Per-CLIN structural, performance, and compliance specs (ANSI/BIFMA, TB 117 flammability, GREENGUARD or BIFMA e3 emissions, TAA, PFOS/PFOA prohibition). Built around the same squadron conference and break room scenario, with eight CLIN-by-CLIN spec blocks ready to tailor.

↓ Download (DOCX)

          One word of caution. The template is a starting point, not a finished document. The salient characteristics, evaluation factors, and price-reasonableness language all need tailoring to your actual requirement. Cross-check your local agency clause matrix (each component layers its own supplements on top of FAR Part 8) before posting.
        

Contract File Checklist

What you should have in your file for an above-SAT GSA schedule order. More documentation than under-SAT — check them off as you go.

GSAM 538.71 — FSS Ordering Procedures

The ordering procedures for GSA Federal Supply Schedules — including 538.7103-3 for above-SAT orders and 538.7104-3 for sole source justifications.

Open GSAM 538.71

FAR 8.4 — Federal Supply Schedules

The FAR subpart on GSA schedules. Post-RFO, it directs you to GSAM 538.71 for ordering procedures.

Open FAR 8.4

GSA eBuy

Post RFQs to FSS contractors. The primary competition method for above-SAT GSA orders.

Visit GSA eBuy

GSA Advantage

Search for FSS contractors with active schedules. Useful for market research even when eBuy is your competition vehicle.

Visit GSA Advantage

GSA eLibrary

Search GSA schedule contracts by contractor or product category. Verify schedules are current.

Visit GSA eLibrary

FAR Part 8 Deviation Guide (RFO)

The official RFO deviation guide explaining what changed in FAR Part 8 and where the ordering procedures moved.

Open Part 8 Deviation Guide