What a contracting officer checks before awarding you a contract
Before awarding any federal contract, the contracting officer must make an affirmative determination that you are a responsible prospective contractor — FAR 9.104-1 requires adequate financial resources, ability to meet the delivery schedule, a satisfactory performance record, a satisfactory record of integrity and business ethics, the necessary organization and technical skills, and the necessary equipment and facilities. This checklist breaks that evaluation into 50 items across 12 sections so you can see your bid the way your buyer does.
What is a responsibility determination?
Before award, the contracting officer must affirmatively determine that the prospective contractor is responsible under FAR 9.104-1. If they cannot make that determination on the available information, FAR requires them to determine the contractor non-responsible — silence counts against you, which is why documentation matters as much as capability.
What does a contracting officer actually check?
Under FAR 9.104-1: adequate financial resources or the ability to obtain them, ability to comply with the required delivery schedule, a satisfactory record of past performance, a satisfactory record of integrity and business ethics, the necessary organization, experience, and technical skills, and the necessary equipment and facilities. They also verify your SAM.gov registration is active and your size status fits the solicitation’s NAICS code.
Why do small business bids get rejected?
The most common avoidable reasons are administrative, not technical: an expired SAM.gov registration, size status that doesn’t fit the solicitation’s NAICS code, missing set-aside certifications, or an incomplete proposal that fails a submission requirement. These are screened before anyone reads your technical approach.
Can a contracting officer reject me for having no past performance?
No performance record is treated as neutral, not unfavorable — a new contractor cannot be found non-responsible solely for lack of history. A bad record is different. For small businesses found non-responsible, the SBA's Certificate of Competency program under FAR 19.6 provides a route to challenge that determination.
Does a small business get a second chance after a non-responsibility finding?
Yes. When a contracting officer determines a small business non-responsible, the matter is referred to the SBA, which may issue a Certificate of Competency — a binding determination that the firm is responsible. This is a small-business-only protection under FAR Subpart 19.6.