FAC-C Professional common mistakes
FAC-C Professional · Understand the traps and how to avoid them.
Chooses time-and-materials or cost-plus-fixed-fee as the default contract type whenever the requirement is not perfectly defined, without ever testing the preconditions (adequate accounting system for cost-reimbursement; a ceiling and a surveillance plan for T&M and labor-hour).
Scenarios deliberately describe a vaguely worded requirement, and T&M or CPFF feel 'safer' to candidates than firm-fixed-price. Most candidates memorize contract type definitions but not the conditions that authorize their use.
What to do instead
Before selecting a type, run the FAR Part 16 decision order: firm-fixed-price where the requirement is well defined and risk is manageable; fixed-price incentive or FP-EPA as risk grows; cost-reimbursement only where the contractor has an adequate accounting system and cost-estimating ability, and never without a cost ceiling and Limitation of Cost/Funds clause; T&M or labor-hour only where the extent or duration of work cannot be estimated at award, with a ceiling and mandatory surveillance. Be able to state the specific finding each type requires.
Treats the acquisition plan as a form completed after the requirement and strategy are already fixed, and never analyzes in the plan whether the requirement should be bundled or consolidated, how competition and small business participation will be maximized, or which contract type and source selection approach should follow.
Planning feels like overhead and the exam asks the question at the 'write the plan' stage, so candidates skip the analysis the plan exists to force.
What to do instead
Structure the plan around the FAR Part 7 planning elements and answer each explicitly: background and objectives, market research, competition and set-aside strategy, source selection approach, contract type, and how consolidation or bundling was measured and justified under FAR 7.107. Remember a written plan is generally expected for acquisitions above the simplified acquisition threshold and that the plan is what drives the solicitation strategy.
Cites the wrong statutory authority for other-than-full-and-open competition-for example, using 'only one responsible source' for a situation that is really 'unusual and compelling urgency,' or approving a justification for a sole-source action where full and open competition was in fact feasible.
The seven authorities at FAR 6.302 read almost identically, and scenarios are written to be ambiguous about whether the real cause is urgency or uniqueness.
What to do instead
Memorize the seven authorities by their trigger facts (national security; not separately available/mobilization; unusual and compelling urgency; only one responsible source; industrial mobilization or expert services; standardization; national interest) and test each scenario against the narrowest one that fits. Also know the approval levels, the required contents of the justification, and that the justification must be synopsized except for classified or urgent actions.
Buys straight from the open market or a GSA/VA schedule an item that is on the AbilityOne Procurement List or the FPI schedule, or skips the required sources that sit ahead of schedules in the priority order.
Schedule buying is quick and habitual, and the mandatory-source rules are scattered across FAR Subparts 8.4, 8.6, and 8.7 rather than sitting in one place.
What to do instead
Walk FAR 8.002's priority order before touching a schedule: agency inventories, excess from other agencies, Federal Prison Industries, AbilityOne, then mandatory and optional schedules. Know that FPI and AbilityOne are mandatory sources and that buying elsewhere requires a documented compelling-reason determination (FAR 8.604, 8.700-7).
Performs market research as a single internet search late in the process, documents only 'market research was conducted,' and never uses the findings to shape the requirement, support a commercial-item determination, or justify a set-aside or sole source.
Market research gets treated as a checklist artifact rather than the input that determines the requirement, the competition approach, and the contract type.
What to do instead
Answer the FAR 10.001 questions with evidence-what is available, customary terms and conditions, whether it is commercial, and whether small business can perform-using more than one FAR 10.002 method, and show which decision each finding supports (requirement revision, FAR Part 12 procedures, set-aside, or justification for other than full and open competition). Cite the documentation in the acquisition file.
Runs 'clarifications' with a single offeror that actually address deficiencies or weaknesses in its proposal, effectively letting one offeror improve its proposal without opening discussions with everyone.
Clarifications, communications, and discussions overlap in practice, and the scenario is written so the contact looks harmless and routine.
What to do instead
Apply the test: if the exchange touches a deficiency or weakness that could change the proposal, it is a discussion and must be conducted with every offeror in the competitive range, each of whom must be allowed to revise. Clarifications are limited to minor or clerical errors; communications may only address past performance and experience. Also know when a competitive range must be established and when award without discussions is permissible.
Makes a best-value tradeoff award but writes the decision as 'the highest technically rated offeror is also reasonably priced,' or uses lowest-price-technically-acceptable for a complex, high-risk requirement with subjective evaluation factors.
Best value and LPTA get learned as two labels rather than two different decision rules, and the tradeoff narrative is the hardest document to write under time pressure.
What to do instead
For a tradeoff, state which factors were compared, what the price premium buys, whether that premium is justified, and exercise and document independent judgment in the source selection decision rather than compiling ratings. Reserve LPTA for requirements that are well defined and low risk, where the government would not pay for more than the minimum, and confirm the conditions of FAR 15.101-2 before using it.
Confuses responsiveness with responsibility-rejecting an otherwise acceptable proposal because the offeror lacks financial capability, or rejecting a sealed bid for a responsibility-type concern instead of confirming the bid conformed to the material terms of the invitation.
Both questions are answered before award and both are described as making an offer 'acceptable,' and the exam uses sealed-bid scenarios to test whether the candidate can separate them.
What to do instead
Ask what is being judged. Responsiveness judges the offer against the solicitation's material terms-in sealed bidding, conformance is a pass/fail test at bid opening. Responsibility judges the offeror under FAR Subpart 9.1: capability, financial resources, integrity, tenacity, SAM registration, and past performance/FAPIIS. Remember that an SBA Certificate of Competency can override a non-responsibility determination for a small business except in limited circumstances.
Issues a unilateral modification that adds work or changes terms and labels it 'administrative,' or lets an unauthorized commitment made by a field office stand without a ratification by an official with authority above the contracting officer who should have made it.
Bilateral versus unilateral and administrative versus substantive changes blur in practice, and the ratification rules sit in FAR 1.602-3, far from the modifications coverage candidates study.
What to do instead
Classify every modification first: within scope and truly administrative-unilateral is fine; within scope but changing terms, cost, or quantity-bilateral unless a specific clause permits a unilateral direction (for example, a change ordered under the Changes clause). Out-of-scope work requires a new procurement. For unauthorized commitments, know the ratification path and that the ratifying official must hold authority above the contracting officer; the contractor may still be entitled to an equitable adjustment under the constructive change doctrine.
Terminates for default without giving the required cure or show-cause notice where there is time to cure, ignores excusable delay, or assumes a default termination carries the same settlement entitlement as a termination for convenience.
The grounds and procedural notices feel procedural rather than outcome-determinative, so candidates answer on the bare fact that the contractor failed to perform.
What to do instead
For default, confirm the failure is a material breach or triggers the default clause, issue the required cure or show-cause notice where there is time to cure, and check for excusable causes such as changes, delays, or Government fault. Remember the remedies diverge: default exposes the contractor to excess reprocurement costs and liability, while convenience requires a settlement and cannot be used punitively.