FAR Part 8 and Part 12 Are the Two Regulations You'll See on Every GSA Contracting Exam
If you're preparing for the FAC-C certification through DAU or any GSA contracting credential, the Federal Acquisition Regulation is your primary source. FAR Parts 8 and 12 aren't the only relevant parts — but they're the two that govern the majority of Schedule-based acquisitions, and exam questions return to them constantly. This guide breaks down both parts in the depth you need for exam success.
What Is the FAR and How Is It Structured?
The Federal Acquisition Regulation (FAR) is the primary regulation governing federal government acquisitions. It's codified at Title 48 of the Code of Federal Regulations and consists of 53 parts covering everything from procurement planning and competition requirements to contract types, cost principles, and clauses. Agency-specific supplements — the DFARS for defense agencies, HHSAR for HHS, and others — layer additional requirements on top of the FAR.
FAC-C candidates at all three levels (Entry, Mid, Professional) are expected to navigate the FAR fluently. You won't memorize it — the exam allows reference materials in some formats — but you need to know where to look, what each major part covers, and how specific provisions apply to realistic acquisition scenarios.
FAR Part 8: Required Sources of Supplies and Services
FAR Part 8 establishes a hierarchy of sources that contracting officers must consider before going to open competition. Understanding this hierarchy is foundational for any federal contracting professional:
- Inventories of the requiring agency — Use what you already have before buying more.
- Excess from other agencies — Check the Federal Excess Personal Property program.
- Federal Prison Industries (FPI/UNICOR) — Mandatory consideration for certain products.
- Ability One Program — Products and services from nonprofits employing people who are blind or severely disabled (formerly Javits-Wagner-O'Day Act items).
- Wholesale supply sources (GSA stock, Defense Logistics Agency) — Pre-positioned government inventory.
- GSA Multiple Award Schedules — The most commonly used step for agencies that need commercial products and services not available from steps 1–5.
- Open market competition — When none of the above sources satisfy the requirement.
The critical exam point: ordering from a GSA Schedule is not optional once the Schedule is an appropriate source. If the requirement can be satisfied from a Schedule, contracting officers must demonstrate why it wasn't used or obtain a waiver to proceed directly to open market competition. This mandatory consideration aspect of Part 8 is frequently tested.
FAR Part 8.405: Ordering from Schedules
FAR Part 8.405 is the specific subpart governing how agencies order from GSA Schedules. It has two main sections:
8.405-1 (Ordering for supplies or services not requiring a statement of work): For orders that can be placed based on the vendor's published catalog pricing — typically commercial products. Below the micro-purchase threshold ($10,000 as of 2026), agencies can award without competition. From $10,001 to $250,000 (the simplified acquisition threshold), agencies must request quotes from at least three vendors. Above $250,000, agencies must provide a "fair opportunity" to all Schedule vendors offering the relevant services or products.
8.405-2 (Ordering for services requiring a statement of work): For service orders where the agency must define requirements through a statement of work. The same thresholds and competition requirements apply as in 8.405-1, but the solicitation must include an RFQ with the statement of work attached. Evaluation factors beyond price must be considered and documented.
The "fair opportunity" requirement for large orders (above $250,000) is an area that generates many compliance issues. Contracting officers must notify all Schedule holders who offer the required services, allow adequate response time, and document the basis for selection. Sole-source orders above the simplified acquisition threshold require a written exception to fair opportunity — a J&A equivalent for Schedule orders.
FAR Part 12: Acquisition of Commercial Items
FAR Part 12 establishes the policies and procedures for acquiring commercial items — products and services that are sold to the general public or that have been offered for sale in the commercial marketplace. The premise of Part 12 is that commercial items don't need the same level of government oversight, auditing, and compliance as non-commercial contracts.
Part 12 acquisitions use streamlined procedures:
- Solicitations use the Uniform Contract Format simplified for commercial items, with simplified terms and conditions
- Certain standard government contract clauses are replaced with commercial equivalents that are less burdensome
- Cost or pricing data (certified cost data under TINA — the Truth in Negotiations Act) is generally not required for commercial items
- Government audit access rights are limited compared to non-commercial contracts
- Technical data rights provisions are replaced with commercial license terms
Because most GSA Schedule products and services are commercial items, Parts 8 and 12 are deeply intertwined in practice. Schedule orders typically use the commercial item solicitation provisions from Part 12 combined with the ordering procedures from Part 8.
Price Reasonableness on Schedule Orders
Determining that the price paid on a Schedule order is "fair and reasonable" is a required determination for every contracting officer. For Schedule orders, FAR 8.405-2 requires documentation of the basis for the price reasonableness determination. This can include:
- Comparison to prices paid by commercial customers for the same or similar items
- Comparison to prices of similar items on other Schedules
- Comparison to prior government prices for the same or similar items
- Analysis of whether the catalog price itself is fair and reasonable based on commercial market data
Contracting officers cannot simply accept the Schedule price as automatically reasonable — they must make an affirmative determination and document it. This is one of the most common audit findings in GSA Schedule ordering: lack of price reasonableness documentation.
Documenting Schedule Orders for Audit Readiness
FAC-C certification emphasizes documentation because documentation is where contracting officers most often fail in audits and Inspector General reviews. For every Schedule order, the file should contain: market research showing why the Schedule was appropriate, the RFQ issued to vendors, quotes received, the evaluation methodology and results, the basis for vendor selection, and the price reasonableness determination. Missing any of these creates audit exposure regardless of whether the order itself was properly awarded.
Practice FAR Application, Not FAR Memorization
The FAC-C exam tests your ability to apply FAR provisions to realistic scenarios — not recite regulation numbers. Scenario practice is the highest-value study activity once you understand the underlying regulations. SimpuTech's GSA Contracting AI tutor generates realistic contracting scenarios that require you to apply FAR Parts 8 and 12, identify compliance issues, and select the correct course of action. Start practicing free at SimpuTech →
Related reading: GSA Schedule Contracts Explained and How to Pass the FAC-C Certification.
Certification details verified against dau.edu and the FAR at acquisition.gov as of March 2026. Requirements are subject to change — confirm current details before registering.
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