FAR 8.405-1—Ordering procedures for supplies, and services not requiring a statement of work.
Plain-English Summary
FAR 8.405-1 sets the ordering procedures for Federal Supply Schedule (MAS/FSS) supplies and services that are fixed-price and do not require a statement of work, such as installation, maintenance, and repair. It explains when ordering activities may use these streamlined procedures, how to handle purchases at or below the micro-purchase threshold, how to compete orders above the micro-purchase threshold but at or below the simplified acquisition threshold, and how to compete proposed orders exceeding the simplified acquisition threshold. It also covers the special treatment of brand-name specifications, the factors that may be used in best-value decisions, and the minimum documentation that must be retained. In practice, this section is the roadmap for buying schedule items without a full FAR Part 15-style procurement, while still preserving competition, fairness, and a clear audit trail. It matters because it tells contracting officers when they can buy quickly, when they must seek quotes from multiple schedule contractors, when they must post on eBuy, and when a written justification or determination is required. It also ties directly to the broader MAS ordering rules in 8.404, 8.405-4, 8.405-5, 8.405-6, and 8.405-3 for BPAs.
Key Rules
Applies to fixed-price, no-SOW buys
Use this subsection for schedule orders for supplies and services priced at a fixed rate for a specific task when a statement of work is not required. If the acquisition involves BPAs or orders under BPAs, use 8.405-3 instead.
Micro-purchases may be placed flexibly
At or below the micro-purchase threshold, the ordering activity may buy from any schedule contractor that can meet the need. The rule does not require quotes from a set number of contractors, but the activity should try to distribute orders among contractors.
SAT and below require best value and at least three sources or a documented exception
For orders above the micro-purchase threshold but not exceeding the simplified acquisition threshold, the ordering activity must award to the schedule contractor offering the best value. Before ordering, it must either survey at least three schedule contractors or document why fewer than three were reasonably considered under 8.405-6(a).
Over-SAT orders must be competed on a competitive basis
Proposed orders exceeding the simplified acquisition threshold must be competed unless a properly prepared and approved justification waives that requirement under 8.405-6. The RFQ must describe the requirement and state the basis for selection.
eBuy posting or broad distribution is required
For over-SAT orders, the contracting officer must either post the RFQ on eBuy to give all eligible schedule contractors an opportunity to quote or send it to as many contractors as practicable to reasonably ensure at least three quotes from capable contractors. If fewer than three quotes are received, the contracting officer must document why no additional capable contractors could be identified.
Brand-name buys require eBuy posting and justification
If the order includes brand-name specifications, the contracting officer must post the RFQ on eBuy with the required justification or documentation under 8.405-6. A purchase description that specifies a brand name requires an RFQ.
Best value may consider more than price
In addition to price, the ordering activity may evaluate past performance, special features, trade-in value, probable life, warranty, maintenance availability, environmental and energy efficiency, and delivery terms when determining best value.
Minimum documentation is mandatory
The ordering activity must document the schedule contracts considered, the contractor selected, the item or service purchased, the amount paid, compliance with over-SAT ordering procedures, and the basis for the award decision.
Responsibilities
Ordering Activity Contracting Officer
Determine whether the requirement fits 8.405-1, choose the correct ordering path based on dollar value, obtain and fairly consider quotes, post RFQs on eBuy when required, prepare or ensure approval of any required justification or written determination, apply best-value factors, and maintain the required documentation.
Ordering Activity
Use the streamlined schedule ordering procedures appropriately, support market research and competition efforts, and avoid using this section for BPA establishment or BPA orders when 8.405-3 applies.
Schedule Contractors
Respond to RFQs or quote requests when capable of meeting the requirement, provide accurate catalog/pricelist information, and compete for orders when solicited through eBuy or other appropriate means.
Agency/Ordering Organization
Support fair opportunity and competition, ensure internal controls and documentation practices are in place, and encourage reasonable distribution of micro-purchases among capable schedule contractors.
Practical Implications
This section is designed for speed, but the level of competition and documentation increases as the dollar value rises. A common mistake is treating an over-SAT order like a simple quote request and skipping eBuy, the three-contractor effort, or the required written determination.
Brand-name requirements are especially sensitive: if the purchase description names a brand, the RFQ and justification/documentation must be posted on eBuy. Failing to do so can create protest and audit risk.
For SAT-and-below buys, the rule is not just to get quotes; it is to make a best-value decision based on reasonably available information and to document why fewer than three contractors were considered if that happens.
The minimum documentation list is not optional and is often the first thing auditors ask for. Missing the schedule contracts considered, the award basis, or evidence of compliance for over-SAT orders can undermine the file even if the purchase itself was otherwise proper.
Contracting officers should also watch the boundary between this section and 8.405-3 for BPAs, since using the wrong ordering procedure can invalidate the acquisition approach or create compliance issues.
Official Regulatory Text
(a) Ordering activities shall use the procedures of this subsection when ordering supplies and services that are listed in the schedules contracts at a fixed price for the performance of a specific task, where a statement of work is not required ( e.g., installation, maintenance, and repair). For establishing BPAs and for orders under BPAs see 8.405-3 . (b) Orders at or below the micro-purchase threshold . Ordering activities may place orders at, or below, the micro-purchase threshold with any Federal Supply Schedule contractor that can meet the agency’s needs. Although not required to solicit from a specific number of schedule contractors, ordering activities should attempt to distribute orders among contractors. (c) Orders exceeding the micro-purchase threshold but not exceeding the simplified acquisition threshold . Ordering activities shall place orders with the schedule contractor that can provide the supply or service that represents the best value. Before placing an order, an ordering activity shall: (1) Consider reasonably available information about the supply or service offered under MAS contracts by surveying at least three schedule contractors through the GSA Advantage! on-line shopping service, by reviewing the catalogs or pricelists of at least three schedule contractors, or by requesting quotations from at least three schedule contractors (see 8.405-5 ); or (2) Document the circumstances for restricting consideration to fewer than three schedule contractors based on one of the reasons at 8.405-6 (a); (d) For proposed orders exceeding the simplified acquisition threshold. (1) Each order shall be placed on a competitive basis in accordance with (d)(2) and (3) of this section, unless this requirement is waived on the basis of a justification that is prepared and approved in accordance with 8.405-6 . (2) The ordering activity contracting officer shall provide an RFQ that includes a description of the supplies to be delivered or the services to be performed and the basis upon which the selection will be made (see 8.405-1 (f)). (3) The ordering activity contracting officer shall - (i) Post the RFQ on eBuy to afford all schedule contractors offering the required supplies or services under the appropriate multiple award schedule(s) an opportunity to submit a quote; or (ii) Provide the RFQ to as many schedule contractors as practicable, consistent with market research appropriate to the circumstances, to reasonably ensure that quotes will be received from at least three contractors that can fulfill the requirements. When fewer than three quotes are received from schedule contractors that can fulfill the requirement, the contracting officer shall prepare a written determination explaining that no additional contractors capable of fulfilling the requirement could be identified despite reasonable efforts to do so. The determination must clearly explain efforts made to obtain quotes from at least three schedule contractors. (4) The ordering activity contracting officer shall ensure that all quotes received are fairly considered and award is made in accordance with the basis for selection in the RFQ. (e) When an order contains brand-name specifications, the contracting officer shall post the RFQ on eBuy along with the justification or documentation, as required by 8.405-6 . An RFQ is required when a purchase description specifies a brand-name. (f) In addition to price (see 8.404 (d) and 8.405-4 ), when determining best value, the ordering activity may consider, among other factors, the following: (1) Past performance. (2) Special features of the supply or service required for effective program performance. (3) Trade-in considerations. (4) Probable life of the item selected as compared with that of a comparable item. (5) Warranty considerations. (6) Maintenance availability. (7) Environmental and energy efficiency considerations. (8) Delivery terms. (g) Minimum documentation . The ordering activity shall document- (1) The schedule contracts considered, noting the contractor from which the supply or service was purchased; (2) A description of the supply or service purchased; (3) The amount paid; (4) When an order exceeds the simplified acquisition threshold, evidence of compliance with the ordering procedures at 8.405-1 (d); and (5) The basis for the award decision.