6.3 Competition Requirements & JOFOCs (FAR Part 6)

6.3 Competition Requirements & JOFOCs (FAR Part 6)

Quick Answer: FAR Part 6 requires full and open competition with competitive procedures unless a recognized other than full and open authority applies. Exceptions need justification and approval (JOFOC) themes: facts, market research, and maximizing competition. Prefer competition; never treat leadership preference as a statutory exception.

Competition is both a Guiding Principle (earlier chapters) and a hard Part 6 procedure set. Plan Solicitation competency expects you to convert market research and acquisition planning into a lawful competition strategy—or a defensible limited-competition path.

Full and open competition as the default

Full and open competition means all responsible sources are permitted to compete. The Contracting Officer must promote and provide for full and open competition in soliciting offers and awarding contracts unless a Part 6 exception (or another authorized pathway consistent with the FAR) applies.

Why the default exists:

Exam mindset: If the stem does not clearly establish an exception, choose the answer that preserves or expands competition.

Competitive procedures (high level)

When providing for full and open competition, Part 6 recognizes competitive procedures such as:

Sealed bid vs competitive proposal (exam-level contrast)

You do not need to litigate every Part 14 vs 15 edge case on CON 3990V, but you must know: both can implement full and open competition, and choosing proposals is not automatically “less competitive” than bids when conditions call for negotiation.

Other than full and open competition — authority themes (FAR 6.302 family)

Part 6 permits contracting without providing for full and open competition only when a listed circumstance applies. Learn the themes (principle level). Exact statutory cross-cites matter less on a closed-book workforce exam than recognizing the category and the documentation duty:

Critical limits on exceptions

1. Exceptions are exclusive categories. Leadership preference, incumbent familiarity, and poor planning are not independent authorities.
2. Urgency still requires maximizing competition practicable under the circumstances—single-source urgency awards need facts about why others could not be solicited.
3. Only one source demands market research that truly supports uniqueness; restrictive specifications can create artificial “only one” outcomes—and that is on the Government.
4. Public interest is not the everyday tool for routine buys; treat it as extraordinary.
5. Statutory authority means an actual statute—not a local memo titled “policy.”

JOFOC documentation themes (justification and approval)

When using other than full and open competition, the file needs a justification (often called a JOFOC—Justification for Other than Full and Open Competition) and approval at the level required by Part 6 / agency procedures based on dollar value and circumstance.

You should not invent precise approval-dollar ladders unless verified for the current FAR text, but you must know conceptual content themes justifications typically address:

Insufficient JOFOC language: “Incumbent is doing a good job and changing vendors would be inconvenient.” Stronger pattern: Specific capability that others lack after documented market research; mission harm if delayed; steps taken to compete to the maximum extent practicable; plan to compete next time if barriers can be removed.

Approval culture (conceptual)

Higher dollar values and certain authorities demand higher-level approvals (competition advocates, senior procurement executives, or other designated officials under Part 6 structure). On the exam: do not award before required justification approval. If schedule pressure collides with approval lead time, escalate early—do not skip the signature.

Promoting competition even when limited

Part 6 is not binary “compete everything or sole source forever.” Even under exceptions:

• Solicit multiple sources when practicable (especially urgency).
• Avoid unnecessary brand-name-only or restrictive specs.
• Structure follow-on acquisitions to restore competition (data rights, transition, modular contracting concepts at awareness level).
• Use advance planning (Part 7) so urgency exceptions are rare rather than routine.

Competition advocates and similar roles exist in the FAR system to challenge barriers—exam scenarios may reward consulting them when sole-source pressure is unjustified.

Scenario drills (CON 3990V style)

Scenario A — Preference vs authority. A director orders “sole source to Company Z; they sponsor our conference.” Answer path: Refuse; preference and sponsorship are not Part 6 authorities; pursue full and open or a valid set-aside path; ethics concerns may also apply.

Scenario B — Urgency after poor planning. The requiring activity delayed the package six months and now claims 6.302-2 urgency the week before funds expire. Answer path: True urgency can exist, but self-inflicted delay is scrutinized; still maximize competition practicable; document facts carefully; leadership should own the schedule failure without inventing national-security language.

Scenario C — Only one source. Market research identifies three firms that sell equivalent commercial solutions; the program wants brand-name-only for comfort. Answer path: Not 6.302-1; compete using brand-name-or-equal or performance specs; if brand-name truly required, justify restrictiveness properly—do not skip competition.

Scenario D — Method choice. Specs are clear, award can be based on price to a responsible bidder, and time allows advertising. Someone insists on a complex Part 15 tradeoff “because we always negotiate.” Answer path: Consider whether sealed bidding conditions are met; competitive proposals are not automatically better or more “professional.”

Scenario E — JOFOC without research. A draft justification asserts only one source but attaches no market research. Answer path: Incomplete; complete Part 10 research and rewrite justification with facts—or compete.

Linking Parts 6, 7, and 10

If research shows competition is available, the plan and JOFOC cannot honestly claim otherwise. If the plan promises full and open competition, the solicitation method must deliver it.

Closed-book cues

• Stem about full and open, JOFOC, sole source, urgency exception, only one responsible source → Part 6
• Stem about whether to use sealed bids vs negotiation at strategy level → Part 6 competitive procedures + later Part 14/15 detail
• Stem about documenting why not competed → justification content + market research linkage
• Stem about who must approve → higher-level approval concept tied to value/authority (agency implementation)

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Bottom line: FAR Part 6 defaults to full and open competition via competitive procedures (sealed bids, competitive proposals, and other authorized competitive methods). Other than full and open requires a real 6.302-family circumstance, a fact-based JOFOC, proper approval, and maximum practicable competition even then. On CON 3990V, convenience, preference, and poor planning are not authorities—promote competition and document honestly when an exception truly applies.