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Sign inConfirmed authorities, paste-ready language, and the action register for federal sales.
Every authority below was verified against acquisition.gov on 12–13 August 2026: FAR FAC 2026-01 effective 13 March 2026, AFARS Change 2025-0711. This document is internal. It contains competitor identification and an assessment of where our own arguments fail, and it is not published, deployed, or shared with a customer.
Read firstDoD is executing under Revolutionary FAR Overhaul class deviations rather than the published FAR, and clause numbers are in motion. Two renumbers are confirmed under DoD Class Deviation 2026-O0025, effective 1 February 2026: FAR 52.204-21 is now FAR 52.240-93, and DFARS 252.204-7020 is now DFARS 252.240-7997.
Rule: never cite a clause number to a contracting officer without asking them to confirm deviation-current numbering first. A stale citation in our paperwork reads as a firm that does not follow the regulation it is quoting.
| Figure | Value | Authority | Status |
|---|---|---|---|
| Micro-purchase threshold | $15,000 | FAR 2.101, current at FAC 2026-01, effective 13 Mar 2026 | Confirmed. Our figure was right. |
| MPT, services under SCLS | $2,500 | FAR 2.101; 41 U.S.C. 6702(a)(2) | Resolved. Not applicable to a sole-performer contract — 29 CFR 4.113(a)(1). See §11. |
| SDVOSB sole source, other NAICS | $5,000,000 | FAR 19.1406(a)(2)(ii) | Confirmed. Our figure was right. |
| SDVOSB sole source, manufacturing | $8,500,000 | FAR 19.1406(a)(2)(i) | Not applicable to 611430. |
| SF 182 per-slot ceiling | $25,000 | AFARS 5113.270-90(g); DoDI 1400.25 Vol. 410 | Applies to individual slots only. See §06. |
| Certified cost or pricing data | Not required at or below SAT | FAR 15.403-1(a) | Part 15 does no work for us below SAT. |
Held upThe two numbers the whole pricing model rests on — $15,000 and $5,000,000 — are both correct as published on the site. No repricing is forced by the threshold check itself.
Two corrections to what this section used to sayFirst, FAR 13.003(c)(2) was the wrong authority for the travel problem. That provision prohibits breaking one requirement into several purchases; folding travel into a single price is the opposite of splitting, and no rule forbids it. The travel problem is plain arithmetic on the aggregate under FAR 2.101, nothing more. Second, and more important: the micro-purchase threshold is not the binding constraint at all. The cardholder’s delegated single purchase limit is, and we do not set it, cannot see it, and often cannot find it out before quoting. GSA guidance is explicit that agencies need not set limits at the FAR maximum. A cardholder delegated $10,000 is out of reach at any price we would accept.
Third correction, on the practical point: a not-to-exceed travel line is fatal to a card purchase at any price, not just at $15,000. A card charge is a determinate amount at the moment it is run; a cost-reimbursable ceiling is not. Any catalog line meant for the card must carry travel inside a firm fixed price with no Federal Travel Regulation or Joint Travel Regulations reference on it — invoking the FTR signals a cost-reimbursable element and invites exactly the separate-CLIN treatment that breaks the arithmetic.
Implemented 13 Aug 2026A distinct catalog item now sits on both the public card and the programs page: half day, up to 15 participants, delivered within 60 miles of Springfield, Virginia, $14,500 all-inclusive, travel inside the price, no add-on lines, no FTR reference. It is deliberately a separate scope rather than a discount on the standard half day, so that a reviewer comparing a $14,500 card buy against a $49,000 buy thirty days later reads two different products rather than one requirement split in two. The standard half day remains $15,000 plus travel and is bought by purchase order. The 60-mile radius is our choice, not a rule — it covers Belvoir, Quantico, Meade, Myer, McNair, Bolling and the Pentagon. Confirm it before it is published.
$500 of headroom, 3.3 percent. It absorbs a sales tax, an excise charge or a non-appropriated fund facility fee, each of which lands inside the aggregate. It is not there for travel.
Do not build the program around this laneThe recommendation on the record is to publish the $14,500 local item as a convenience and nothing more. For any delivery outside the local radius the arithmetic does not close: Springfield to Fort Hood is roughly $1,500 to $2,500 for one person for one delivery, which absorbed inside $14,500 is a 10 to 17 percent haircut on top of 3.5 percent in card fees. That is selling a $13,500 class and calling it a $15,000 class. Do not attempt the card lane at Fort Hood. One further consequence worth weighing: FAR 13.003(b)(1) requires acquisitions above the micro-purchase threshold and at or below the simplified acquisition threshold to be set aside for small business. Leaving the card lane lands us in a reserved lane, which is not a penalty.
A BPA under FAR 13.303 removes us from the micro-purchase lane rather than stretching it. FAR 13.303-5(b) holds individual purchases to the simplified acquisition threshold, and AFARS Appendix EE 8-3(c)(2) lets a Contract Ordering Official cardholder order training available under an established contract, including a BPA, up to their delegated limit for that authority — $25,000 or $250,000. That is card-paid ordering an order of magnitude above a $15,000 ceiling, at the cost of one contracting action to establish it. It is the strongest move available on the whole acquisition question.
Two cautions. FAR 13.303-5(c) is explicit that a BPA does not justify sole-sourcing or avoiding a small-business set-aside, and the requirements of FAR 13.003(b) and subpart 19.5 apply to each order. And establishing a BPA is a representation that the requirement is recurring — which is right for a BPA and fatal to any later claim that two micro-purchases were unrelated one-offs. Pick one lane and stay in it.
FAR 2.101 · FAR 13.003(b)(1) · FAR 13.201(b) · FAR 13.303-5(b), (c) · AFARS App. EE 8-3(c)(2)
FAR 13.201(b) makes the purchase card the preferred method for micro-purchases, and the threshold tests against the aggregate amount of the acquisition, which is the price actually charged rather than list. FAR 2.101 defines a micro-purchase as an acquisition “the aggregate amount of which does not exceed” the threshold, so $15,000 exactly qualifies.
Aggregate amount captures the whole requirement. FAR 13.003(c)(2) and AFARS 5113.270-90(b) forbid dividing a requirement to get under the threshold, and AFARS Appendix EE 8-3(f) Example 2 is directly on point: a $30,000 group course for 150 participants cannot be divided by 150 to reach a $200 per-student price and paid as 150 separate slots — the MPT applies to the aggregate cost.
FAR 2.101 · FAR 13.003(c)(2) · AFARS 5113.270-90(b) · AFARS App. EE 8-3(f)
Breaks a live claimThe half day for up to 15 is priced at exactly $15,000 with travel billed separately at cost. Any travel at all puts the aggregate over the threshold, and the after-action package is now inside the delivery price and no longer a separate line, so it cannot. As published, the card lane closes the moment we leave home.
Recommended fix, and the recommended figure: $14,500 all-inclusive, travel absorbed, no add-ons, no separately priced after-action report. The $500 of headroom absorbs a rounding error or a card surcharge. See §12 for the exact rate-card wording.
FAR 19.1406(a)(1) requires that the contracting officer “does not have a reasonable expectation that offers would be received from two or more service-disabled veteran-owned small business concerns.” FAR 19.1406(b)(1) requires SAM designation as an SBA-certified SDVOSB. Our certification leg is clean: SBA VetCert, 2 June 2026, renewal 2 June 2029.
Valens Global LLC — UEI LALHWS52EG66, GSA MAS 47QREA20D000B, SBA-certified SDVOSB — sells in NAICS 611430 and its GSA catalog lists “Simulation (Non-Customized)” under SIN 611430. Air Force award FA714624P0011 was a tailored in-person tabletop exercise. A five-minute GSA eLibrary search by a contracting officer defeats a no-reasonable-expectation finding if the requirement is stated generically.
The tensionThe finding survives only if the requirement is written around our proprietary method. A requirement drafted to one vendor’s proprietary product then invites the objection that it is unduly restrictive of competition. We cannot hold a broadly stated requirement and a no-reasonable-expectation finding at the same time, and we should stop trying to.
Below the simplified acquisition threshold the exposure is smaller, because FAR Part 6 justification machinery is not triggered and the contracting officer documents under FAR 13.106-3(a)(2). The restrictiveness objection survives at any dollar value.
This also settles the open question from last week. Valens Global is a competing SDVOSB in our own code, so the half-day positioning has to rest on the method being proprietary rather than on the market being empty.
Our citation was wrong in one place worth correcting: FAR 15.403-1(c)(2) is prices set by law or regulation. The commercial exception is FAR 15.403-1(c)(3). Below SAT the point is academic, because FAR 15.403-1(a) bars obtaining certified cost or pricing data at or below the simplified acquisition threshold at all.
The catalog price definition sits in FAR 2.101 under commercial service ¶(6)(i): a price in a list regularly maintained by the vendor, published or available for inspection, stating prices at which sales are currently or were last made to a significant number of buyers constituting the general public. There is no numeric minimum and the contracting officer decides. FAR 13.106-3(a)(2)(iii) states the limit outright: inclusion of a price in a price list, catalog, or advertisement does not, in and of itself, establish fairness and reasonableness.
FAR 2.101, commercial service ¶(6)(i) · FAR 13.106-3(a)(2)(iii) · FAR 15.403-1(a), (c)(3)
The “of a type” route permits treating a service as commercial where it is not sold competitively in substantial quantities, provided the contracting officer determines in writing that sufficient information was submitted to evaluate price reasonableness. Pair the published card with the federal comparables already in comparators.json.
Discount disciplineThe 10 percent first-engagement price survives as a stated, uniform, non-recurring discount from list. Reduced from 20 percent on 16 Aug 2026, before any customer had seen the card. It defeats the catalog claim if every buyer pays 80 percent, because then 80 percent is the catalog price and list is fiction. Cap it: one engagement, first-time institutional customer only, and document every grant. The current site wording — “available to every customer on their first order” — is one adjective away from the problem.
Our principal teaches a six-day, three-credit graduate course at Georgetown University for which the university pays approximately $10,000, and one day of that course is a simulation. That figure has to be kept away from the catalog, and the reason it can be is that it is not a sale by Red Teaming Associates at all. It is compensation paid by a university to a member of its own faculty for teaching a course the university owns, enrolls, accredits, schedules and hosts. There is no vendor, no customer, no quotation and no contract.
The question to be ready for“You teach Georgetown a six-day course with a simulation in it for ten thousand dollars. Why is two days here forty-nine?” The answer is short. Georgetown is not a customer, it is an employer, and that $10,000 is salary paid to an individual for classroom instruction of the university’s own enrolled degree candidates, who pay the university tuition. It buys no scenario written to a command’s region and authorities, no adversary cell, no facilitation team, no assessment product, no travel, and no license. Red Teaming Associates furnishes none of those things to Georgetown and bills Georgetown for nothing.
Three rules follow, and they are absolute. The Georgetown engagement never appears as past performance of the firm, never appears as a price comparable in any basis-of-price paragraph, and never appears on the rate card — not as an academic rate, not as a discount, not as a footnote with a number in it. It appears only where it belongs: as the teaching experience of the principal, in his biography and in the capability statement, described as a faculty appointment rather than as a contract.
SettledOwnership is confirmed: the syllabus, the simulation and the scenario architecture used in the Georgetown course are the principal’s intellectual property, not the university’s. That closes the work-for-hire question and leaves the private-expense assertion in the license addendum and the work statement standing.
The one thing worth keeping on file is the documentary basis — the appointment letter, the relevant faculty handbook provision, or written correspondence with the university — because a contracting officer relying on the private-expense representation may ask what supports it. Note also that ownership and funding source are separate claims: Georgetown paid salary for teaching, and the platform was built by the firm, so both hold. Keep them stated that way.
SAM shows a single prior award to the firm: purchase order H9224312P1111, $30,000 obligated, signed 25 July 2012, Department of Defense / U.S. Special Operations Command, contracting office H92243 Naval Special Warfare Group Two. That award does real work for us. It is documented evidence that the firm has sold to the federal government, which supports the responsibility finding at FAR 19.1406 and gives the “sales made” leg of the catalog argument something to stand on.
It is a comparable, and the gap is wideThe award description reads only “TRAINING, VILLAGE STABILITY OPERATIONS”, with a period of performance of 25 July to 10 August 2012, NAICS 541618 and PSC U099. No day count appears in the record. That is instructor-led classroom teaching, which is the same product family as the card — so a contracting officer can and probably will use it.
No per-day figure can honestly be derived: the record states no day count, and the 17-day period of performance is not one. The cheapest cell on the current card works out to $30,000 per day, the two-day program for 16–25 participants also $30,000 per day, and the half day for 26–35 reaches $44,000 per day. That is a five- to seven-fold increase per day. Get the 2012-to-2026 factor from the BLS CPI calculator; inflation explains part of the gap and nowhere near all of it.
The rest of the gap is scope, and the answer has to be specific. The 2012 course delivered classroom instruction on a subject. The card delivers a crisis written to a named command’s region, adversary and authorities; a staffed adversary cell adjudicating against the room’s own decisions; a facilitation team; a same-day written assessment of each participant’s reasoning; and twelve months of cohort access to a platform that did not exist in 2012. Write that comparison down once, in those terms, and keep it with the price reasonableness file. It is the single most likely challenge to the card and it is answerable.
AFARS 5113.270-90(g) says what we thought it said: use the purchase card as a method of payment for all commercial training $25,000 and below, on an SF 182 under 5 U.S.C. chapter 41 for civilians or a DA Form 2171 for soldier tuition assistance. AFARS Appendix EE Chapter 8 then splits training into three categories, and a group class bought as a whole lands in the wrong one.
| Category | Rule | Us |
|---|---|---|
| 8-2 Individual slots | Not a FAR-based transaction, MPT does not apply, $25,000 per SF 182, one SF 182 per student, no bulk SF 182s | Only if we publish an open-enrollment course |
| 8-3 Group training | Subject to the MPT. 8-3(e): the purchase of an entire group session is subject to the MPT even if each student has an SF 182 | This is what we sell today |
| 8-4 Tailored | Must go to contracting | Anything scenario-tailored |
Corrected in the toolA $49,000 group class cannot ride SF 182 or the purchase card. It exceeds the MPT and goes to MICC. Two further limits: 5 U.S.C. chapter 41 is the Government Employees Training Act and covers civilian employees, so a brigade of soldiers largely cannot use the lane at all; and AFARS 8-2(d)(2) requires a regularly scheduled off-the-shelf course, available to the public, priced the same for everyone in the category, requiring no tailoring.
AFARS 8-4(c) is favorable: setting a date and time for a commercial off-the-shelf class, or offering one on the installation, is not considered tailored, and cardholders may buy a course initially developed for an organization that is now offered off the shelf. Publish scheduled dates and a per-slot price and civilian employees anywhere in the Army can enroll individually up to $25,000 each, with no aggregate MPT ceiling and no contracting officer.
Strategic forkThat requires a per-seat number on the website, which cuts directly against the band-pricing decision taken to keep the buy from reading as a software license. This is the only unlimited-aggregate lane available to us. It is a decision to take deliberately, not a fix to apply. A separate open-enrollment product with its own per-seat price, sitting alongside the banded tailored programs, keeps both arguments intact.
DFARS 252.239-7010 is prescribed at DFARS 239.7604(b) for information technology services, and the Cloud Computing SRG obligation at DFARS 239.7602-1(b)(1) applies to acquiring cloud computing services from a provider with DISA provisional authorization. Neither attaches to instruction. Both attach instantly if the PSC or the work statement calls this an IT service or a platform subscription. That is the whole reason the product service code matters.
DFARS 204.7304(c) prescribes 252.204-7012 in all solicitations and contracts including Part 12, except those solely for COTS items. Same default for 252.204-7008 and 252.204-7019 / 252.204-7020 (now 252.240-7997). Expect all of them in the document. Work statement language buys scope rather than exclusion: with no covered defense information provided or generated, the safeguarding obligations have nothing to operate on and NIST SP 800-171 compliance stays outside our boundary.
Assume CMMC Level 1The Level 1 trigger is Federal Contract Information, not CUI, and we hold FCI the moment there is a roster, a work statement and contract correspondence. On 13 July 2026 the Department suspended CMMC Phase 2 (DoD CIO and USD(A&S) memoranda, publication case 26-P-1023), but Phase 1 Level 1 and Level 2 self-assessments remain in effect, 32 CFR part 170 is unamended, and DFARS 252.204-7021 remains in force. The 60-day review from that memo has run. Verify the outcome before filing anything. This is the most volatile item in the package.
FAR 39.201(a) implements Section 508 (29 U.S.C. 794d) and the Access Board standards at 36 CFR 1194.1. FAR 39.201(c) requires agencies acquiring ICT to ensure federal employees with disabilities have comparable access. Federal employees using a web interface during class sits squarely inside that.
The instrument is an Accessibility Conformance Report, in practice the ITI VPAT version 2.5 completed against the Revised 508 Standards. The buyer needs it when the requirements documents are prepared and before award, because the contracting officer must state applicable accessibility standards in the requirement and document any exception before proceeding. Have it before quoting.
Verify numberingFAR Part 39 is inside FAR Case 2026-001 rulemaking, proposed 23 June 2026, comments closed 23 July 2026. The current numbering of the exception and documentation provisions within Subpart 39.2 was not independently verified. Check 39.203 through 39.205 against the deviation text MICC is using.
Use U008. Accept U009 or U001. Reject anything in the D or 70 series. In the FY22–FY26 award record for NAICS 611430 facilitated training and exercise buys the codes actually used are U008, U009, U001 and U005 — including Maxwell Leadership’s SOCOM seminar (H9242126PE019, 611430/U008), OMNA International’s staff rides (611430/U008), and Upslope Advisors’ Army War College wargame developer award (W91QF026PA013, U008 through MICC Carlisle Barracks). U008 pairs naturally with 611430 and routes to a training buyer.
The cautionary exampleExperiencePoint, LLC, a simulation vendor selling much what we sell, was coded on Army award W91QF022P0036 as NAICS 511210 / PSC DA10 — business application software. That coding invites DFARS 239.76, a cloud review, and an IT approval chain we have no reason to enter. Actively harmful codes: DA10, DF10, 7030, 7A21, and the D-series R-codes. State the intended code in our capability information so the requiring activity puts it on the purchase request.
FAR 12.212(b) gives the Government only the rights specified in the license in any contract addendum. DFARS 227.7202-3(a) is to the same effect for commercial computer software, and 227.7202-1(c)(2) bars requiring us to relinquish rights to use, modify, reproduce, release, perform, display, or disclose it. Those provisions protect the platform. They do not by their terms reach a custom scenario written under contract, which is a written work rather than delivered software.
Read the clause list before signingThe clauses a contracting officer reaches for by default are DFARS 252.227-7014 (noncommercial computer software) and 252.227-7013 (technical data, noncommercial items), which hand the Government unlimited rights in anything developed exclusively at Government expense. On a Part 12 commercial services buy they should never appear, but they are muscle memory and they get pasted in. If either shows up, ask for it to be struck as inconsistent with FAR 12.301(a) and the commercial-item determination.
The answer is a regulation, not a hope29 CFR 4.113(a)(1): where it is contemplated that the services will be performed individually by the contractor, and the contracting officer knows when concluding negotiations that service employees will in no event be used, the Act is not applicable and the clauses required by 29 CFR 4.6 may be omitted. That is a Department of Labor implementing regulation promulgated by the agency that administers the statute — not our assertion against a contracting officer’s. It is a stronger card than an opinion letter, and the search for an opinion letter should stop.
Supporting: 41 U.S.C. 6701(3)(C) excludes from “service employee” anyone employed in a bona fide executive, administrative or professional capacity as defined in 29 CFR part 541. Two independent routes apply to the principal — 29 CFR 541.101, business owner holding at least a 20-percent equity interest and actively engaged in management, which sidesteps the salary-basis test entirely and is the cleaner of the two; and 29 CFR 541.301(a), learned professional.
Two things not to doDo not cite 29 CFR 541.303, the teachers exemption. It requires the employee be engaged as a teacher in an educational establishment by which the employee is employed. Red Teaming Associates is not an educational establishment. It is the intuitive citation, it is wrong, and a labor advisor will catch it.
Do not put AFARS Appendix EE 8-3(b) in front of a contracting officer as coverage authority. It exists and it says group training is subject to the MPT and not to SCLS — but it is Army purchase-card operating procedure, a routing instruction telling a cardholder which ceiling to apply. Coverage is not the Army’s to determine. FAR 22.1003-1 is explicit that the form of contract is not determinative of coverage, and FAR 22.1003-4(a) routes exemption questions through the agency labor advisor to the Wage and Hour Administrator. A DOL investigator is free to disregard AFARS, and back-wage liability runs against us, not the Army. Use 8-3(b) only to explain why an Army cardholder applies the MPT.
Where this breaksThe moment a second facilitator, adversary-cell operator or assessor performs who is neither an owner-employee nor a genuine learned professional under part 541, coverage attaches to the contract as a whole — not merely as to that person — and the threshold for that buy falls to $2,500. 29 CFR 4.156 is the warning: employees failing the part 541 tests are covered even though highly paid, and it names laboratory technicians and draftsmen as examples. Credentials do not do the work; the tests must actually be met. That same person is simultaneously the FAR 52.219-14 self-performance problem. One person, two failure modes, one fix: make them an owner-employee or do not use them.
If SCLS did apply, the consequence that costs most is not the wage rate. It is FAR 52.222-43, price adjustment for wage determination movement across an option period — it converts a published catalog price into a number that moves without our consent. If SCLS risk is ever real, reconsider whether to offer option years at all.
Implemented 13 Aug 2026The generated work statement now carries a §10.4, Service Contract Labor Standards — non-applicability, ending in the load-bearing sentence: “No service employee will be used by the Contractor in the performance of this contract.” That sentence is the mechanism by which the contracting officer knows, which is what 4.113(a)(1) requires and what makes a non-applicability determination defensible rather than assumed. The equity percentage is left as a field to fill — supply it once and it stops being a blank.
Also changed in the work statement, because the old wording argued against us: “adversary-cell operation” now reads adjudication of consequences arising from participant decisions, and PRS-05 now reads reached by professional interpretive judgment against the named analytic standard rather than by mechanical application of a score sheet. 29 CFR 541.301(b) distinguishes work requiring advanced knowledge from routine mental or manual work — “assessment scoring” had written the disqualifying phrase into our own scope.
29 CFR 4.113(a)(1) · 29 CFR 4.156 · 29 CFR 541.101 · 541.301 · 41 U.S.C. 6701(3)(C), 6702(a) · FAR 22.1003-1 · FAR 22.1003-4(a) · FAR 22.1006(a)(1)
AFARS Appendix EE 8-3(b) states that group training is a FAR-based transaction subject to the MPT and not subject to SCLS. That is Army purchase-card guidance rather than a Department of Labor determination, and the contracting officer’s labor advisor can still call it the other way. DOL’s SCA Directory of Occupations carries a 15000-series instructional family that an advisor can map an instructor to; if a wage determination is incorporated we inherit conformance obligations and price-adjustment exposure on a firm-fixed-price contract. Ask the contracting officer for a written non-applicability determination on the professional-employee exemption before award. Valens Global’s GSA price list states the point affirmatively for its own 611430 offerings, which is useful precedent.
The card runs to 30 September 2027. A base year awarded September 2026 plus a twelve-month option is performed into FY28, and option prices must be established at award. Either extend the card’s validity or publish option-year escalation.
An LCDR USNR selling to the Army. While on active duty orders, including ADT and any period making you a special Government employee under 18 U.S.C. 202(a), 18 U.S.C. 203 and 205 restrict representing another party before a federal agency for compensation, and the Joint Ethics Regulation adds outside-activity constraints. Separate from the §207 posture, which is clean here: 1st Air Cavalry Brigade has no nexus to OIG Strategic Initiatives and the standing no-OIG-work rule is not implicated. Have a Navy ethics counselor paper the reserve question, and do not sign while on orders.
FAR 52.204-24, -25 and -26 will be in the solicitation. Confirm the hosting provider and every upstream service in the delivery stack are clear of covered telecommunications equipment before representing. Our stack is Netlify, Google Firebase and the Anthropic API; each needs to be checked and the answer written down once.
On an SDVOSB set-aside or sole source for services, at least 50 percent of the amount paid must go to employees of the concern. A subcontracted second facilitator, a red-cell operator, or outsourced hosting counted as contract cost can breach this on a two-person firm. This is a second, independent reason to be careful about the 26–35 band, which is the one that needs a second facilitator.
FAR 52.204-21, now FAR 52.240-93 under the Part 40 deviation, imposes fifteen safeguarding requirements on any contractor information system that processes, stores, or transmits Federal Contract Information. “No CUI” does not get us out. FCI is the lower bar and we will hold it.
Contractor badging, background vetting, DBIDS enrollment, AT Level I and iWATCH are schedule items that requiring activities routinely leave out of the requirement package, and they can slip a first delivery by weeks. Put access requirements in the work statement as a Government-furnished item with a stated lead time.
Retire todayIt lists a different individual as president and describes the firm as minority-owned. In circulation, that document is an SDVOSB eligibility-protest exposure under 13 CFR part 125 on a sole-source award premised on your control as the qualifying service-disabled veteran. It is not in this project’s files, so it is living somewhere else — a shared drive, an old proposal, a capability statement attached to an email. Find every copy and pull it.
Verbatim, as drafted. Each block names where it goes.
Half-day delivery, on-site, up to 15 participants — $14,500 all-inclusive. Price includes facilitation, all participant materials, platform access for the cohort, and contractor travel and per diem. No separately billed charges. Offered at this price to all customers.
These are Red Teaming Associates’ established commercial rates, regularly maintained, published at programs.redteamingassociates.com/pricing, and offered on the same terms to commercial and government customers. The first-engagement price is a one-time, non-recurring 10 percent discount from list available once to a first-time institutional customer; it is not the price at which sales are ordinarily made.
Market research identified no other source able to provide a facilitated crisis decision-making exercise built on a proprietary adjudication engine, scenario architecture, and reasoning-assessment instrument developed at private expense and not licensed or otherwise available to any other vendor. The instructional method — live consequence generation adjudicated against the session record, scored against a published analytic standard — is not a service offered by other concerns in NAICS 611430, which principally offer scripted or pre-scripted exercises. The contracting officer therefore does not have a reasonable expectation that offers would be received from two or more service-disabled veteran-owned small business concerns capable of meeting this requirement.
This is instructor-led professional and management development training. The Contractor does not deliver, install, or transfer any software, software license, or information technology system to the Government. No Government data or Government-related data is created, ingested, stored, processed, or transmitted by the Contractor. No covered defense information or controlled unclassified information is provided to or developed by the Contractor. Participants access instructional content through a commercial, publicly available website using a standard web browser on the open internet, in the same manner as any member of the public; this access is incidental to instruction and is not a cloud computing service, information technology service, or software deliverable procured by the Government. No cloud computing service is being acquired within the meaning of DFARS 239.7601, and no Government information system is hosted, operated, or accredited under this requirement. The Contractor requires no access to Government networks, systems, or accounts.
Participants reach instructional content through a commercial, publicly available website using a standard web browser. The Contractor has not evaluated that interface against the Revised Section 508 Standards and makes no conformance claim about it; no Accessibility Conformance Report is offered under this requirement. Instructional content and participant materials are available in accessible alternate formats on request. Where a participant cannot use the web interface, the facilitator relays the material to that participant and records their decisions on their behalf, so that no participant is excluded from the instruction or from the assessment. The Contractor will support any accommodation the Government identifies in advance of the session.
Anticipated NAICS: 611430, Professional and Management Development Training. Anticipated PSC: U008 — Education/Training: Training/Curriculum Development. This is a training service. No information technology, software, or cloud service is being acquired.
(a) The simulation engine, adjudication architecture, scenario framework, facilitator materials, and reasoning-assessment instrument are commercial items developed exclusively at private expense, are not delivered to the Government, and are furnished solely as commercial computer software and commercial computer software documentation under the Contractor’s standard commercial license, attached as Addendum [X]. The Government receives only the rights stated in that license (FAR 12.212; DFARS 227.7202-1, 227.7202-3).
(b) Scenario content prepared to Government specification under this contract is licensed to the Government, not assigned. The Government receives a perpetual, irrevocable, royalty-free, worldwide license to use, reproduce, modify, display, and perform that scenario content for Government purposes, including delivery by Government-certified facilitators. The Contractor retains ownership and all rights not expressly granted.
(c) After-action reports and participant assessment products prepared specifically for the Government under this contract are delivered with unlimited rights.
(d) DFARS 252.227-7013 and 252.227-7014 are not applicable to this commercial services acquisition.
Open enrollment — scheduled sessions. Crisis Decision-Making Practicum, two days. Published sessions: [dates]. $2,400 per seat. Open to the public. Standard course, no tailoring. SF 182 and equivalents accepted; GPC accepted as method of payment.
| Item | Action |
|---|---|
| SF 182 lane | Done. The builder no longer routes a group class to SF 182; it now states AFARS App. EE 8-3(e) and sends the buy to a contracting officer. Do not offer the $25,000 lane in the room. |
| Cardholder limit | Ask before quoting to the card. The cardholder’s delegated single purchase limit, not the $15,000 threshold, decides whether a card buy is possible. Agencies need not set it at the FAR maximum. This kills more $15,000 designs than travel does. |
| RFO deviation set | Ask the contracting officer which class deviation the office is executing under before putting any FAR Part 13 or Part 22 section number in a document. DoD Class Deviation 2026-O0029 implements RFO Part 13; whether a Part 22 deviation exists is unconfirmed. |
| Equity percentage | Supply the principal’s equity interest so §10.4 of the work statement stops carrying a blank. The 20-percent floor at 29 CFR 541.101 is what the exemption turns on. |
| Card-lane claim | If the purchase card comes up, offer the local all-inclusive half day at $14,500 and nothing else. Do not quote $15,000 plus travel, and do not attempt the card lane at Fort Hood. |
| Installation access | Ask COL Gunter’s staff who owns badging and DBIDS lead time. It is a schedule item, and asking makes us look like we have done this before. |
| Clause numbers | Cite no clause number in the room. Offer to send the paperwork instead. |
| PSC | Done. The vendor block now reads U008 · U009 · U001, leading with the training code. It was U004 · U008 · U001. |
| Item | Action |
|---|---|
| Half-day reprice | Decide on $14,500 all-inclusive with travel absorbed and no add-ons. Rate card, builder rates, and the aggregate warning all change together. |
| Discount discipline | Done 16 Aug 2026 — the card and the builder now read “first-time institutional customer, once, documented.” Still to do: start a grant log. |
| Catalog claim | Reframe on the “of a type” route. Add FAR 13.106-3(a)(2)(iii) awareness to the basis-of-price paragraph so it does not overclaim. |
| Work statement | Add the nature-of-services, accessibility, data-rights and Government-furnished-access paragraphs to the generator. |
| ACR / VPAT 2.5 | Commission one against the Revised 508 Standards. Nothing else in this list blocks a sale as directly. |
| CMMC Level 1 | Verify the outcome of the 13 July 2026 review, then file the Level 1 self-assessment in SPRS. |
| Georgetown IP | Ownership confirmed — syllabus, simulation and scenario architecture are the principal’s. Keep the documentary basis on file (appointment letter or faculty handbook provision) in case a contracting officer asks what supports the private-expense representation. |
| RTA Facts sheet | Find every copy and retire it. |
| Ethics counsel | Paper the reserve-status question with a Navy ethics counselor. |
| Item | Action |
|---|---|
| SCLS determination | Written non-applicability determination on the professional-employee exemption, from the contracting officer. |
| Section 889 | Check Netlify, Firebase and the Anthropic API against covered telecommunications equipment. Write the answer down once. |
| 52.219-14 | Work the 50-percent math for any delivery using a subcontracted facilitator or red-cell operator. |
| Option years | Extend rate-card validity past 30 September 2027 or publish escalation. |
| Clause list | Read it before signing. Strike 252.227-7013 and -7014 if they appear. |
Open-enrollment per-seat course. The only lane with no aggregate ceiling and no contracting officer, and the only one that puts a per-seat price on the website. Recommendation: publish it as a separate product with its own name and its own price, keeping the banded tailored programs untouched, so the per-seat number never attaches to a tailored buy.
Settled 13 Aug 2026Academic customers are carved out of the card entirely. The published claim now reads “offered on the same terms to commercial and government customers” — academic is gone from it, in all five places it appeared. Universities, war colleges and research institutes are agreed directly, off-card.
Why it had to change rather than simply discounting: the catalog basis for price reasonableness rests on that one sentence being true. A university paying a fraction of the card rate while the card claims the same terms to academic customers makes the sentence false, and it is the sentence the price reasonableness determination stands on. Carving the class out keeps the claim true for the customers it is actually offered to.
What makes the academic engagement a different thing rather than the same thing cheaper, and this must stay stated on the card: an established crisis rather than one authored to a command’s region and authorities, a student cohort rather than a body of principals, no bespoke authoring, no installation access, and no assessment package addressed to a contracting officer’s representative. If an academic engagement ever includes those, it is not an academic engagement and the card applies.
Open with the FAR advisor. Whether customer-class pricing at roughly a quarter of the government rate weakens the FAR 15.403-1(c)(2) catalog basis even when published separately and applied uniformly; what the card must say about the scope difference for both to coexist; and how an academic rate interacts with basis-of-award and price-reduction obligations if a GSA schedule is ever held.
Settled 13 Aug 2026The after-action package is inside every delivery price. It was a $9,500 add-on. It could not be both an optional line a client declines and a performance requirement the Government holds us to, and it is the differentiator we lead with. Published delivery prices did not move, so the change costs $9,500 a delivery where a client would have bought it and protects the catalog’s stability inside its stated validity window.
A commissioned crisis is $35,000, down from $55,000. At $55,000 it was 92 percent of a two-day class for 25, which reads as a product that is not finished until the customer pays twice — and it contradicted our own capability statement, which says tailoring is the method rather than an option priced on top. At $35,000 it is 58 percent of a delivery. Three weeks of authoring puts it near $11,700 a week, so it is defensible on labor as well as on proportion.
Added 13 Aug 2026A three-day program is published at $66,000 / $81,000 / $92,000 by class-size band, capped at 35 participants. Basis: the third day adds facilitation and adjudication only — scenario preparation, mobilisation and travel are already paid by the first two — so it is the two-day rate plus 70 percent of its average day. The per-day rate therefore falls as days rise, which is what a buyer expects to see. The 36-to-50 band was rounded down from $101,000 to keep it off the six-figure line. The 10 percent first-engagement discount applies to all four cells.
What neither decision rests onMarket data. One comparable is on file — a two-day facilitated workshop reported at $63,000 — with no award identifier and no link, so by our own rule it cannot be shown or cited. Our $60,000 sitting $3,000 under it is a coincidence that looks like positioning. Verified comparables now exist — see the author page. Argue per delivery; the per-day evidence in NAICS 611430 runs against us. Both prices above are set on internal proportion, and they should be revisited the moment a sourced comparable exists.
Loaded from the authoring endpoint, not from a file in the public site. Maintained per price-comparison-workflow.md — a weekly pass, fifteen minutes. An entry without an award identifier and a link is not evidence and is shown here as unverified so it is never carried into a package by mistake.
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Before any of this goes in a packageUse obligated amounts, never potential value — the difference is often several multiples and it is the first thing a contracting officer checks. Compare like shapes only: a two-day facilitated exercise against a two-day facilitated exercise, never against a multi-year support contract or a software license. Do not divide a multi-delivery award by one delivery's days to manufacture a per-day rate. And state their award and ours, then stop — the comparison should read as a fact we are helping them verify, which is why the link travels with it.
Our own 2012 award is the comparable to be ready forPurchase order H9224312P1111, $30,000, 2012, USSOCOM through Naval Special Warfare Group Two, day count not stated in the record. Inflation covers a fraction of it; pull the factor from the BLS calculator. The rest is scope, and the answer has to be itemized: the 2012 course was classroom instruction on a subject; the card delivers a crisis written to a named command's region and authorities, a staffed adversary element adjudicating against the room's own decisions, a facilitation team, a same-day written assessment of each participant's reasoning, and twelve months of platform access for a platform that did not exist in 2012. Written down in those terms it holds. Left as “the scope was different,” it does not.