If you take the logic from my previous post on Non-Competitive clearance and try to apply it directly to a Competitive Source Selection, you are going to get confused fast. The terminology is the same, but the “gates” move.
In a sole-source environment, we are clearing the negotiation strategy. In a competitive environment, we are clearing the solicitation structure and the evaluation process. Because we must treat all offerors fairly (FAR 1.602-2), the government cannot simply “negotiate” on the fly. We have to stick to the script written in the Request for Proposal (RFP).
Here is how the Clearance Approval Authority (CAA) controls the gates in a competitive buy under DAFFARS 5301.90.
Business Clearance = Permission to Solicit
In a competitive acquisition, Business Clearance is the approval to issue the solicitation (RFP).
Why do we need clearance just to ask for quotes/proposals? Because once that RFP hits the street (SAM.gov), the government is legally bound to evaluate proposals exactly as described in Section M (Evaluation Factors). If your Section L (Instructions) and Section M don’t align, or if your evaluation criteria are ambiguous, you are setting yourself up for a pre-award protest.
At Business Clearance, the CAA reviews:
- Section L & M: Are the instructions to offerors clear? Is the basis of award (LPTA vs Trade-off) clearly defined?
- The Acquisition Strategy: Does this match the Acquisition Plan previously approved?
- Evaluation Team Structure: Do we have the right people (SSEB) ready to grade the homework?
Contract Clearance: The Two-Step Dance
Contract Clearance in a competitive environment is trickier because it depends on whether you hold “Discussions” (negotiations) or award on “Initial Proposals.”
Scenario A: Award Without Discussions
If you receive great proposals and do not need to negotiate, Contract Clearance is the approval for the Source Selection Authority (SSA) to make the final award decision.
Scenario B: Award With Discussions (The Standard)
If you enter discussions (establish a Competitive Range), Contract Clearance is actually split or revisited. According to DAFFARS 5301.9000, you need approval to:
- Request Final Proposal Revisions (FPR): Before you close discussions and ask for “Best and Final Offers,” the CAA must review your evaluation of the initial proposals and your discussion ENs (Evaluation Notices). They want to ensure you didn’t accidentally coach one vendor or evaluate another unfairly.
- Make the Source Selection Decision: After FPRs are received and evaluated, the CAA gives the final nod for the SSA to sign the Source Selection Decision Document (SSDD).
The Cheat Sheet: Competitive Clearance Flow
| Stage | Action Being Approved | Why it Matters |
| Business Clearance | Issuing the RFP (Solicitation) | Locks in the rules of the competition. |
| Contract Clearance (Step 1) | Requesting Final Proposal Revisions (FPR) | Ensures discussions were meaningful and fair. |
| Contract Clearance (Step 2) | Source Selection Decision (SSDD) | Verifies the winner was chosen according to Section M. |
Regulatory Reference
Always cite your source. The Air Force specifics for this are found in:
- DAFFARS 5301.9000(a): Defines Business Clearance for competitive acquisitions as “approval to issue the solicitation.”
- DAFFARS 5301.9000(e): Defines Contract Clearance for competitive acquisitions regarding FPRs and the SSA decision.
Pro Tip for KOs: Do not treat the “Request for FPR” clearance as a rubber stamp. If your CAA finds an error in how you conducted discussions (e.g., misleading an offeror), you cannot fix it after FPRs are submitted without re-opening discussions for everyone. This is your last safety net before the final decision.