Reading a sole-source justification, and the date the lock ends
A justification is the government explaining in writing why one company got the work without a competition. It also tells you for how long.
What the document is
Full and open competition is the default for federal contracts. When an agency awards without it, the contracting officer has to justify the decision in writing, have it approved at a level that rises with the dollar value, and post the justification. For most awards it has to be posted within 14 days after award. When the reason was urgency, the agency has 30 days. On SAM.gov these appear as notices of the type Justification.
Orders have their own version. An order under a multiple-award contract placed without giving every holder a fair opportunity, and a GSA schedule order limited to one source, each need a written justification, and above the simplified acquisition threshold those are posted too.
The authorities, and what each means to a company outside
| Authority | What the agency is saying | How to read it |
|---|---|---|
| Only one responsible source | One company can meet the need and nothing else will do. | The most common. It usually rests on data rights, a qualification or an installed system. Ask what it would take to qualify. |
| Unusual and compelling urgency | There was no time to compete it. | Limited in time. Above the simplified acquisition threshold the contract may not run past one year, options included, unless the head of the agency decides otherwise. |
| Industrial mobilization, research capability or expert services | The award keeps a facility, a capability or an expert available. | Seldom open on the same requirement. |
| International agreement | A treaty, or a foreign government paying for the work, names the source. | Not open. |
| Authorized or required by statute | A law allows or directs the award, as with an 8(a) sole source. | The door is the program, not the requirement. |
| National security | Disclosing the need would compromise national security. | You will seldom see one posted. |
| Public interest | The head of the agency has determined that competition is not in the public interest in this case. | Rare. |
Three ways the same authority is cited
Every justification cites the authority it relies on, and the citation tells you which row of the table you are in. You will see it written three ways. The codified FAR numbers the seven authorities 6.302-1 through 6.302-7. The overhaul text that agencies began adopting in 2025 numbers the same seven 6.103-1 through 6.103-7. And many documents cite the statute instead: 10 U.S.C. 3204 for defense agencies and 41 U.S.C. 3304 for civilian ones, paragraphs (a)(1) through (a)(7). They are the same seven in the same order.
Trust the citation over the wording. The phrase "only one responsible source" can appear in the boilerplate of a document that goes on to cite a different authority.
What else is in it
The FAR lists what a justification has to contain. Five of the items are worth reading every time.
- The description and the estimated value. What is being bought and for how much.
- Why this contractor. The showing that its qualifications, or the nature of the buy, require the authority cited. This is where the barrier is named: proprietary data, a certification, a system already in place.
- The market research. What the agency did to look for other sources and what it found.
- Who expressed interest. A list of the sources that wrote in. If your company wrote in and is not on it, ask why.
- What happens next time. A statement of the actions the agency may take to remove or overcome barriers to competition before it buys the same thing again.
Finding the date the lock ends
A justification covers one award with a period of performance. That period, with its options, is how long the lock lasts. Look for it in the description of the action or in the text: a period of performance through a date, a base and option periods, or a fiscal year. Sometimes the document says when the agency intends to compete the follow-on. Sometimes it gives no date, and you have to take it from the award record once the award is reported.
Sort what you find by that end date, not by the day the notice was posted. A justification posted last week for work that runs three more years is a date three years out. The time to act is the year before it, while the next acquisition is being planned.
Sole source in LastAwarded lists justifications by the date the period ends, with the company, the office, the authority cited and the value where the document states them. A field the document does not state is left empty.
The mistakes, and what to do instead
- Reading it as news. By the time it is posted the award is made. Its value is the date and the barrier.
- Ignoring repeats. One justification is an event. Several to the same company from the same office, year after year, is a barrier that stays until somebody removes it.
- Treating it as a fight. The useful response is nearly always to qualify. Protest deadlines are short, and that is a question for counsel, not for this article.
On Monday, search SAM.gov for Justification notices from your target offices over the last two years. For each, record the company, the authority, the value and the end date. Read the barrier and decide whether you could remove it. Then write to the contracting officer named on the notice, well before the end date, and ask what the agency would need to see to consider a second source.
Related pages
- Sole sourceJustifications sorted by the date the period ends.
- Incumbent profilesEverything else the company holding it has won.
- Recompete radarThe other kind of end date worth a calendar entry.
- Contracting peopleThe contracting officers named on the notices.
See who was last awarded in your NAICS
Every code, every buying office, every vendor and every recompete, organized from the federal record and read nightly. Open it with a plan.