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Best Value Determination Doesn't Comply with High Value, Sole-Source IDIQ Requirements


In the first published decision to interpret the selection criteria applicable to high value, sole-source, IDIQ contract awards, in CW Gov't Travel, Inc. v. U.S. the Court of Federal Claims made clear that the government is required to determine, per FAR 16.504(c)(1)(ii)(D), that the awardee is the only source that is qualified and capable of performing the work at a reasonable price before awarding a sole-source, IDIQ contract over $103 million. Because the government had based its award decision on best value criteria instead, the CFC ruled for the protester.

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