Sole-Source Contracting Under FAR 19.1406: A Contracting Officer's Decision Framework
FAR 19.1406 gives contracting officers authority to award sole-source contracts to SDVOSBs without full competition. Most COs underuse it because they are unsure about documentation. Here is the decision framework and what goes in the contract file.
Sole-source authority under FAR 19.1406 is the most underused tool in the CO's acquisition toolkit. It closes awards 30 to 45 days faster than competitive set-asides. It requires less documentation than a full J&A. And in FY2025, SDVOSB sole-source awards grew to over 7,400 actions -- a 58% increase from FY2020.
The growth reflects a simple reality: acquisition workforce shortages are getting worse, not better. COs managing more actions with fewer staff need compliant paths to fast awards. Sole-source to a VetCert-verified SDVOSB is one of the fastest.
The Three Conditions (All Must Be Met)
A CO exercises sole-source authority under FAR 19.1406 when:
- Only one VetCert-verified SDVOSB can satisfy the requirement at a fair and reasonable price
- The anticipated award value does not exceed $5M (manufacturing NAICS) or $5M (all other)
- The SDVOSB is a responsible contractor with a reasonable expectation of performance
The first condition is the critical one. If two or more SDVOSBs can satisfy the requirement, the CO must use competitive set-aside procedures under FAR 19.1405. Sole-source is specifically for markets where one qualified vendor exists.
In BioPreferred product categories, this condition is frequently met. The intersection of SDVOSB certification and BioPreferred product lines narrows the vendor pool dramatically. In many cleaning chemical subcategories, fewer than three SDVOSB distributors carry certified biobased products.
