MARKET RESEARCH

Better Documentation 

Needed to Inform 

Future Procurements 

at Selected Agencies

Report to the Subcommittee on 

Financial and Contracting Oversight, 

Committee on Homeland Security and 

Governmental Affairs, U.S. Senate

October 2014

GAO-15-8

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-15-8, a report to the 

Subcommittee on Financial and Contracting 

Oversight, Committee on Homeland Security 

and Governmental Affairs, U.S. Senate

October 2014

MARKET RESEARCH

Better Documentation Needed to Inform Future 

Procurements at Selected Agencies

is

Why GAO Did This Study

The federal government spends 

hundreds of billions of dollars annually 

to acquire goods and services from the 

private sector to support agency 

missions. Market research—the 

process used to collect and analyze 

data about capabilities in the market 

that satisfy agency needs—is critical to 

inform decisions about how best to 

acquire these goods and services. 

GAO was asked to examine how 

federal agencies conduct and use 

market research. This report assesses 

(1) selected agencies’ market research 

guidance and policy and (2) how 

selected agencies conducted market 

research on selected procurements.

GAO reviewed federal regulations and

market research policy and guidance 

at DOD, DHS, and DOT—three 

agencies GAO selected based on 

fiscal year 2012 contract obligations 

and the mix of products and services

procured. GAO also reviewed policies 

and guidance issued by the FAA, 

which is not subject to the Federal 

Acquisition Regulation. To assess how 

market research was conducted on 

individual contracts, GAO reviewed a 

nongeneralizable sample of 28 

contracts selected based on dollar 

value and analyzed contract files.

What GAO Recommends

To inform future acquisitions, GAO

recommends that the Secretary of 

Transportation update its market 

research guidance and the Secretaries 

of Defense and Homeland Security 

take action to ensure their acquisition 

personnel clearly document the basic

elements of the market research that 

was conducted. The agencies 

concurred with these 

recommendations.

What GAO Found

Market research guidance at the Departments of Defense (DOD), Homeland 

Security (DHS), and Transportation (DOT) and the Federal Aviation 

Administration (FAA) is consistent with federal regulations in terms of market 

research objectives and builds on the techniques for communicating with industry 

outlined in federal regulations. All four agencies require that market research be 

clearly documented and note that documentation can inform current and future 

procurements. GAO found, however, that the agencies’ guidance varied on the 

specificity of market research documentation. For example, DOD, DHS, and FAA 

guidance identify specific market research elements to be documented. Based 

on analysis of these market research elements, GAO identified four elements 

which, if recorded, would provide an understanding of the research completed. 

These elements include the market research methods used, when it was 

conducted, an analysis of vendor capabilities, and a conclusion. DOT’s market 

research guidance did not require specific elements to be documented, which 

increases the risk that it would not be available to inform future procurements. 

All 28 contracts GAO reviewed included some evidence of the market research 

conducted. The market research conducted on the 12 higher dollar contracts 

GAO reviewed tended to be more robust and include more techniques that 

involved outreach to vendors—such as issuing requests for information to 

industry—which appeared to help promote competition. Agencies did not take 

advantage of many available market research techniques on the 16 lower dollar 

contracts GAO reviewed and as a result may have missed opportunities to 

promote competition (see figure).

Figure: Market research techniques for 28 contracts GAO reviewed 

GAO also identified limitations in the market research for seven DOD and DHS 

lower dollar contracts that appeared to be incomplete or outdated. For example, 

DHS relied on incomplete information regarding potential vendors’ ability to meet

its requirement for parking services. Further, in 14 of the 28 contracts, the four 

agencies did not document one or more of four basic elements that GAO’s 

review of agency guidance identified as important to the ability to understand the 

research. GAO identified this shortfall most often on lower dollar contracts 

reviewed at DOD and DHS. Internal control standards state that significant 

events need to be clearly documented so as to ensure management directives 

are carried out. Not documenting basic elements of the market research

potentially limits the ability of agency acquisition personnel to use market 

research to inform future procurements, a goal identified in agency guidance. 

View GAO-15-8. For more information, contact 

Timothy J. DiNapoli at (202) 512-4841 or 

dinapolit@gao.gov.
Page i GAO-15-8 Market Research

Letter 1

Background 5

Selected Agencies’ Market Research Guidance Is Generally 

Consistent with Federal Regulations, but Documentation 

Requirements Vary at Some Agencies 9

Selected Agencies May Have Missed Opportunities to Promote 

Competition and Inform Future Procurements on Lower Dollar 

Contracts 17

Conclusions 29

Recommendations for Executive Action 31

Agency Comments and Our Evaluation 31

Appendix I Objectives, Scope, and Methodology 33

Appendix II Comments from the Department of Defense 39

Appendix III Comments from the Department of Homeland Security 41

Appendix IV Comments from the Department of Transportation 43

Appendix V GAO Contact and Staff Acknowledgments 44

Tables

Table 1: Market Research Techniques Identified in the Federal 

Acquisition Regulation (FAR) and Agency Guidance 11

Table 2: Description of 28 Selected Contracts Reviewed by GAO 37

Figures

Figure 1: Market Research and the Acquisition Process 6

Figure 2: Required and Recommended Market Research 

Elements as of July 2014 15

Contents
Page ii GAO-15-8 Market Research

Figure 3: Market Research Techniques and Competition Results 

on 28 Contracts GAO Reviewed 18

Figure 4: Number of Contracts Whose Documentation Includes or 

Excludes Basic Elements 25

Abbreviations 

CBP Customs and Border Protection 

DHS Department of Homeland Security 

DLA Defense Logistics Agency 

DOD Department of Defense 

DOT Department of Transportation 

FAA Federal Aviation Administration 

FAR Federal Acquisition Regulation 

FHWA Federal Highway Administration 

FPDS-NG Federal Procurement Database System – Next Generation

OMB Office of Management and Budget 

OPO Office of Procurement Operations

This is a work of the U.S. government and is not subject to copyright protection in the 

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without further permission from GAO. However, because this work may contain 

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Page 1 GAO-15-8 Market Research

441 G St. N.W.

Washington, DC 20548

October 9, 2014

The Honorable Claire McCaskill

Chairman

The Honorable Ron Johnson

Ranking Member

Subcommittee on Financial and Contracting Oversight

Committee on Homeland Security and Governmental Affairs

United States Senate

The federal government spends hundreds of billions of dollars each year 

to acquire goods and services through the commercial marketplace to 

enable agencies to fulfill their missions. These needs range from simple 

goods readily available in the marketplace, such as office supplies, to 

services such as janitorial services, to complex goods and services such 

as information technology systems. Market research—the process used 

to collect and analyze data about capabilities in the market that could 

satisfy an agency’s needs—is a critical step in the acquisition process, 

informing key decisions about how best to acquire goods and services. 

For example, effective market research can help agencies determine the 

availability of vendors to satisfy requirements; knowledge of marketplace 

suppliers and prices can be critical to the government’s ability to negotiate 

a good deal and foster competition. On the other hand, poor market 

research techniques could lessen the government’s ability to achieve 

competition and negotiate fair and reasonable prices.

You asked us to assess how federal agencies are conducting and using 

market research. This report assesses (1) selected agencies’ guidance 

and policy on market research and (2) how selected agencies conducted 

market research on selected procurements. To assess agency guidance 

and policy on market research, we reviewed and identified criteria for the 

conduct and use of market research in government-wide regulations and 

policy, such as the Federal Acquisition Regulation (FAR), including FAR 

Subpart 7.1—Acquisition Plans and FAR Part 10—Market Research, and 

Office of Management and Budget (OMB) memorandums related to 
Page 2 GAO-15-8 Market Research

market research.1 To assess specific agency guidance and policy and to 

illustrate how market research is performed at agencies of various sizes 

and that procure a range of products and services, we selected three 

departments for the review—the Department of Defense (DOD), the 

Department of Homeland Security (DHS) and the Department of 

Transportation (DOT). We selected these departments based on fiscal 

year 2012 contract obligations—the most recent fiscal year of information 

available when we started our review—and to get a good mix of products 

and services procured. Within each department, we selected two 

components for further review—DOD’s Department of the Army and 

Defense Logistics Agency (DLA); DHS’s Office of Procurement 

Operations (OPO)2 and U.S. Customs and Border Protection (CBP); and 

DOT’s Federal Aviation Administration (FAA) and Federal Highway 

Administration (FHWA)—based primarily on their fiscal year 2012 

obligations. For each department and component, we reviewed guidance 

and policy related to market research, including agency supplements to 

the FAR, market research guides and templates, and policy 

memorandums that reference market research, such as DOD’s Better 

Buying Power policy memorandums. Key agency guidance reviewed 

included DOD’s Defense Standardization Program, Market Research: 

Gathering Information about Commercial Products and Services, SD-5; 

DHS’s Market Research Guide; DOT’s Market Research Guide, 

Acquisition Policy DOT Dash 2010-11; and FAA’s Procurement Guidance 

T3.2.1.2—Market Analysis.3

 1

Office of Management and Budget, Office of Federal Procurement Policy, “Myth-Busting”: 

Addressing Misconceptions to Improve Communication with Industry During the 

Acquisition Process, Memorandum for Chief Acquisition Officers, Senior Procurement 

Representatives, Chief Information Officers (Washington, D.C.: Feb. 2, 2011) and Office 

of Management and Budget, Office of Federal Procurement Policy, “Myth-Busting 2”: 

Addressing Misconceptions and Further Improving Communication During the Acquisition 

Process, Memorandum for Chief Acquisition Officers, Senior Procurement 

Representatives, Chief Information Officers (Washington, D.C.: May 7, 2012).

Since the FAR and DOT acquisition 

regulation do not apply to FAA acquisitions, we analyzed FAA policy and 

2

For the purposes of this report, we considered DHS’s Office of Procurement Operations 

to be a component.

3

While this review focused on guidance applicable across each department and 

separately for FAA, FHWA noted its Acquisition Customer Service Guide contains 

additional information on market research techniques.
Page 3 GAO-15-8 Market Research

guidance separately from DOT.4

To examine how agencies conducted market research on selected 

procurements, we used the Federal Procurement Data System-Next 

Generation (FPDS-NG) to select a nongeneralizable sample of 30 

contracts awarded in fiscal year 2012 with contract dollar values of at 

least $500,000 from the six components within DOD, DHS, and DOT. We 

selected this threshold as the contracts above this threshold represented 

more than 92 percent of contract dollars awarded in fiscal year 2012 at 

each component reviewed. Within each selected agency component, we 

created randomized lists of fiscal year 2012 contracts within two strata—

(1) contracts valued at more than $10 million and (2) contracts valued 

between $500,000 and $10 million. The higher dollar stratum represented

the greatest portion of contract dollars awarded in fiscal year 2012 within 

each component—ranging between 79 percent and 98 percent of dollars, 

while the lower dollar stratum represented a larger portion of contract 

actions awarded in fiscal year 2012. Within each stratum, we selected a 

nongeneralizable sample of contracts to obtain, to the extent possible, a 

mix of products and services and a mix of competed and noncompeted 

contracts within each component. We selected two contracts from the first 

stratum and three from the second stratum (five per component) from the 

randomized lists for each component. Overall, we selected 30 contracts 

for a more in-depth review. We excluded 2 of the 30 selected contracts 

from our final analysis—1 from FHWA and one from FAA—because, as of 

July 31, 2014, we were unable to assess the market research for those 

contracts due to missing market research documentation and staff 

changes since the award of the contracts.

We interviewed senior acquisition 

officials at each department to develop a better understanding of agency 

policies and component guidance related to market research and to 

identify agency initiatives related to market research.

5

 4

For the purposes of this report, we use the term agency policy and guidance to refer to 

that issued by DOD, DHS, DOT, as well as FAA. The FAR does not apply to FAA 

acquisitions pursuant to the Department of Transportation and Related Agencies 

Appropriations Act of 1996, Pub. L. No. 104-50 § 348 (1995).

As a result, our analysis in this 

report is based on 28 selected contracts. For each contract, we reviewed 

5

At the conclusion of our review in August 2014, FHWA officials reported they had located 

the preaward documents for the contract. For the FAA contract, contracting staff were 

unable to locate the market research for the contract. In both instances the staff 

responsible for conducting, documenting, or accepting the market research were no 

longer with the organization. 
Page 4 GAO-15-8 Market Research

contract documents related to market research, including market research 

reports, acquisition plans, justifications and approvals for sole-source 

awards, price negotiation memorandums and independent government 

cost estimates, and interviewed or obtained information from cognizant 

contracting and program officials. The findings from our selected 

contracts are not generalizable to the population of all contracts within the 

selected agencies or components.

To assess the reliability of the FPDS-NG data used to select the contracts 

for review, we compared key data elements from FPDS-NG to the 

contract documentation, including the contract number, agency name, 

and whether or not the contract had been competed using full and open 

competition. Where we found discrepancies relevant to our methodology, 

we made adjustments to maintain the integrity of our selection criteria. 

For example, we excluded 7 contracts because the contracts were 

miscoded in FPDS-NG and therefore should have been excluded from 

our sample. Specifically, we excluded 5 contracts because they were 

small business set asides, 1 contract because the total dollar value fell 

below the $500,000 threshold for inclusion in the review, and 1 contract 

because it was a research and development contract. Because we had 

randomized lists of contracts for each of the components, we replaced the 

miscoded contracts with another contract. Once we corrected for these 

errors, we concluded the data obtained was sufficiently reliable for the 

purposes of this report.

Market research serves several purposes, including identifying sources 

capable of meeting the government’s need, promoting competition, 

identifying whether commercial items can meet the government’s needs, 

and identifying whether small businesses are capable of meeting the 

requirement. For the purposes of our review, we focused our work on how 

market research informed the competition strategy and the contracting 

officer’s analysis of price reasonableness. We did not assess how market 

research informed the small business determination or how it informed 

the decision to use a commercial item given GAO has prior work that 
Page 5 GAO-15-8 Market Research

focuses on these issues.6

We conducted this performance audit from August 2013 to October 2014 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Appendix I provides additional details on our 

scope and methodology.

Market research has been a statutory requirement since the passage of 

the Competition in Contracting Act of 1984, which required the use of 

market research and acquisition planning, and solicitation of proposals, to 

obtain competition.7 The FAR defines market research as the process 

used to collect and analyze data about capabilities in the market that 

could satisfy an agency’s procurement needs. The FAR provides general 

policies and procedures for conducting market research with the goal of 

arriving at the most suitable approach to acquiring, distributing, and 

supporting supplies and services.8

Market research is conducted throughout various phases of an 

acquisition, and involves the program office and the contracting office. 

The program office typically starts the market research in the acquisition 

planning phase once a need is identified. The program office may then 

contact its contracting office to coordinate the development of key 

acquisition documents. The program office is primarily responsible for 

conducting market research in the early phases of an acquisition and 

submitting a formal request for contract to the contracting office. 

Responsibility for market research shifts from the program office to the 

 6

For GAO’s recent work on commercial item determinations, see GAO, Federal 

Contracting: Commercial Item Test Program Beneficial, but Actions Needed to Mitigate 

Potential Risks, GAO-14-178 (Washington D.C.: Feb. 4, 2014). For GAO’s recent work on 

small business contracting, see GAO, Small Business Contracting: Updated Guidance 

and Reporting Needed for Consolidated Contracts, GAO-14-36 (Washington D.C.: Nov. 

26, 2013).

7

Pub. L. No. 98-369, Div. B, tit. VII, § 2711. 

8

FAR § 10.000.

Background
Page 6 GAO-15-8 Market Research

contracting office as the acquisition process progresses (see figure 1). 

Further, the FAR requires that market research be conducted, appropriate 

to the circumstances, before developing new requirements documents. In 

addition, the FAR identifies a number of other points in the acquisition 

process when market research must be conducted, including prior to 

soliciting offers for contracts above the simplified acquisition threshold 

and below this threshold if adequate information is not available and 

circumstances justify its cost.9

Figure 1: Market Research and the Acquisition Process

a

The simplified acquisition threshold is generally $150,000.

b

Bundling refers to the consolidating of two or more requirements for goods or services previously 

provided or performed under separate smaller contracts into a solicitation for a single contract that is 

likely to be unsuitable for award to a small business concern.

 9

FAR § 10.001(a)(2). The simplified acquisition threshold is generally $150,000.
Page 7 GAO-15-8 Market Research

Federal regulations provide some flexibility in terms of how and to what 

extent market research should be conducted, considering the nature of 

the procurement. Specifically, the FAR provides that the extent of market 

research depends on a number of factors, such as urgency, estimated 

dollar value, complexity, and past experience.10

We have issued a number of reports with implications for market 

research. In our 2011 report on acquisition planning, we note that market 

research is a part of the acquisition planning process, a process that is 

responsible for successful acquisition outcomes.

The FAR also states that 

agencies should document the results of market research in a manner 

appropriate to the size and complexity of the acquisition, but does not 

prescribe any particular format or specific elements for documentation.

11 In addition, we issued 

several reports related to the market research objective of promoting 

competition. For example, in a January 2012 report reviewing DOD’s use 

of the national security exception (which allows agencies to limit 

competition for a contract in instances when disclosure of an agency’s 

needs would compromise national security), as well as in a March 2013 

report reviewing DOD’s use of competitive procedures, we found few 

details about the market research findings that helped justify the decision 

to pursue a noncompetitive or limited competition award for some 

contracts reviewed.12 In contrast, our best practices work has shown how 

market research can be used to enhance competition. Specifically, in an 

April 2013 report identifying leading commercial company practices for 

acquiring services, we reported that one company sometimes chose to 

execute a short term contract to buy time if market research showed a 

more competitive deal could be obtained at a later date.13

 10FAR § 10.002(b)(1).

11GAO, Acquisition Planning: Opportunities to Build Strong Foundations for Better 

Services Contracts, GAO-11-672 (Washington, D.C.: Aug. 9, 2011).

12GAO, Defense Contracting: Improved Policies and Tools Could Help Increase 

Competition on DOD’s National Security Exception Procurements, GAO-12-263 

(Washington, D.C.: Jan. 13, 2012); GAO, Defense Contracting: Actions Needed to 

Increase Competition, GAO-13-325 (Washington, D.C.: Mar. 28, 2013).

13GAO, Strategic Sourcing: Leading Commercial Practices Can Help Federal Agencies 

Increase Savings When Acquiring Services, GAO-13-417 (Washington, D.C.: Apr. 15, 

2013).
Page 8 GAO-15-8 Market Research

While market research is one factor that may affect competition, there are 

a number of other factors as well, such as whether the government owns 

the rights to the technical data on a contract and the relationship between 

a program office and a contracting office. For example, in a May 2014 

report reviewing DOD’s noncompetitive and one-offer awards, we found 

that the justifications for half of the noncompetitive contracts and task 

orders stated that the awards could not be competed due to a lack of 

technical data.14 Similarly, in a March 2014 report reviewing the use of the 

unusual and compelling urgency exception to full and open competition at 

three federal agencies, we found that for 10 DOD contracts reviewed, the 

government was unable to compete requirements in part because of a 

lack of access to technical data packages or proprietary data.15 In terms 

of the relationship between the contracting and program offices, in July 

2010 we reported that several agencies recognized that program offices 

place pressure on the contracting process to award new contracts to a 

specific vendor without competition. Further, we reported that many 

contracting officials we spoke with recognized that program staff 

sometimes prefer a specific vendor—often an incumbent—in some cases 

because a relationship has developed between the program office and 

the contractor, who understands the program requirements.16 We also 

found that a strong incumbent, sometimes coupled with overly restrictive 

government requirements, are factors that may contribute to receiving 

only one offer on a competitive procurement.

 14GAO, Defense Contracting: Early Attention in the Acquisition Process Needed to 

Enhance Competition, GAO-14-395 (Washington, D.C., May 5, 2014).

15GAO, Federal Contracting: Noncompetitive Contracts Based on Urgency Need 

Additional Oversight, GAO-14-304 (Washington, D.C.: Mar. 26, 2014).

16GAO, Federal Contracting: Opportunities Exist to Increase Competition and Assess 

Reasons When Only One Offer is Received, GAO-10-833 (Washington, D.C.: Jul. 26, 

2010).
Page 9 GAO-15-8 Market Research

We found that agencies’ market research guidance at DOD, DHS, DOT, 

and FAA is consistent with federal regulations in terms of market research 

objectives, techniques, and documentation, but agencies’ guidance varies 

from one another on the specificity of documentation required. For 

example, DHS guidance requires that specific elements of market 

research be documented and DOD and FAA make recommendations on 

the types of elements to be documented. In contrast, DOT provides 

acquisition staff limited instruction, stating that the level of detail might 

vary based on factors such as whether the market research is for a onetime or recurring requirement but its market research guidance does not 

require any specific elements to be documented. Based on our review of 

agencies’ market research guidance, we identified four basic market 

research elements, which, if recorded, would allow those not connected 

with the research to understand how the acquisition team collected and 

analyzed information about capabilities within the market to satisfy 

agency needs. These four market research elements include (1) the 

methods used, (2) the timeframes when staff used them, (3) an analysis 

of the capabilities of potential sources, and (4) a conclusion based on this 

analysis.

Our analysis found that, consistent with the FAR, selected agencies’

guidance indicates that market research may be used to inform two key 

decisions. The first decision—deciding whether or not to conduct a full 

and open competition—is made as part of the acquisition planning 

process and one of the purposes of market research is to promote 

competition to the maximum extent practicable.17 Federal regulations 

require agencies to perform acquisition planning activities for all 

acquisitions to ensure that the government meets its needs in the most 

effective, economical, and timely manner possible.18 The second 

decision—deciding whether the prices to be paid for the goods or 

services is reasonable—is made prior to the award of a contract. This 

decision is commonly referred to as the “price reasonableness” decision. 

While not required, the FAR identifies market research as a method for 

this purpose.19

 17FAR § 7.102(a).

More specific information about the FAR provisions and 

how agency guidance reinforces them follows:

18FAR § 7.102(a) and (b).

19FAR § 15.404-1(b)(2)(vi).

Selected Agencies’

Market Research 

Guidance Is 

Generally Consistent 

with Federal 

Regulations, but 

Documentation 

Requirements Vary at 

Some Agencies

Selected Agencies’

Guidance Is Consistent 

with FAR Objectives for 

Market Research and 

Provides Additional 

Techniques for 

Communicating with the 

Industry
Page 10 GAO-15-8 Market Research

• Competition: The FAR requires, among other things, that market 

research and acquisition planning be used to promote and provide for 

full and open competition or, if not required, to obtain competition to 

the maximum extent practicable.20 Agencies’ guidance reinforces the 

goal of providing for competition in several ways, for example, by 

instructing acquisition staff to identify and analyze the capabilities of 

potential sources prior to making the competition decision, which 

would include determining whether the requirement should be set 

aside for small business concerns, open to full and open competition, 

or sole-sourced to a specific vendor.21

• Price Reasonableness: The FAR identifies the comparison of 

proposed prices on a contract with prices obtained through market 

research for the same or similar items as one of several methods for 

determining price reasonableness.

DOD and DOT guidance 

explains that market research helps the acquisition team become 

informed consumers, enabling the team to develop the optimal 

procurement strategy. DHS guidance notes that market research 

should be used to refine requirements to maximize the benefit of 

competitive market forces, as needed, and to consider if modifying a 

requirement may allow a commercial, rather than a noncommercial, 

item to be acquired.

22

Agencies’ guidance builds upon the market research techniques identified 

in the FAR by identifying a greater variety of ways of communicating with 

industry and emphasizing the importance of doing so.

Agencies’ guidance confirms the 

usefulness of market research in informing what price would be 

reasonable for the government to pay for a procurement. For 

example, FAA guidance states that market research and analysis can 

help ensure that the government’s needs are met in a cost effective 

manner based on understanding prices in the commercial 

marketplace. DOD guidance similarly explains that knowledge of 

market pricing information is necessary for planning for contract 

obligations and determining price reasonableness.

23

 20FAR § 7.102(a)(2). The FAR also directs that the results of market research are to be 

used to determine if sources capable of satisfying the agency’s requirements exist. FAR § 

10.001(a)(3)(i).

The market 

21Subpart 6.3 of the FAR specifies the conditions under which an agency may award a 

contract to a single source without providing for full and open competition. The award of 

such a contract can be referred to as a sole-source award. 

22FAR § 15.404-1(b)(2)(vi).

23Section 10.002(b)(2) of the FAR lists techniques for conducting market research.
Page 11 GAO-15-8 Market Research

research techniques described in the FAR, as well as those in agencies’

guidance, can be broadly categorized as those used by acquisition staff 

to (1) obtain information from internal sources, such as reviewing the 

results of recent market research undertaken to meet similar or identical 

requirements, or (2) communicate directly with external sources, 

particularly industry sources (see table 1).

Table 1: Market Research Techniques Identified Under Part 10 of the Federal Acquisition Regulation (FAR) and in Agency 

Guidance 

FAR DOD DHS DOT FAA

Internal Information

Reviewing the results of recent market research undertaken to meet similar or identical 

requirements

    

Contacting knowledgeable government officials on market capabilities to meet requirements, 

including obtaining source lists of similar items from other contracting activities or agencies 

    

Querying the government-wide database of contracts and other procurement instruments 

intended for use by multiple agencies available at www.contractdirectory.gov/contractdirectory/

and other government and commercial databases 

    

Reviewing catalogs and other generally available product literature published by 

manufacturers, distributors, and dealers or available on-line

    

Reviewing prior acquisition history 

External Information

Contacting knowledgeable industry officials on market capabilities to meet requirements or 

obtaining source lists of similar items from trade associations or other sources

    

Conducting interchange meetings or holding presolicitation conferences to involve potential 

offerors early in the acquisition process

    

Publishing formal requests for information in appropriate technical or scientific journals or 

business publications

   

Participating in interactive, on-line communication among industry, acquisition personnel, and 

customers 

  

Holding one-on-one meetings with industry    

Publishing requests for information or sources sought notices at www.FedBizOpps.gova   

Attending trade fairs and conferences   

Performing site visits (program staff visiting vendors or vendors visiting the agency)   

Preparing a formal survey or questionnaire and sending it to multiple suppliers   

Sponsoring industry conferences or industry days  

Source: GAO analysis of part 10 of the FAR and of agency guidance. | GAO-15-8

a

Federal Business Opportunities, commonly referred to as FedBizOpps, is a web-based government 

portal which allows all potential vendors to consider federal procurement opportunities.
Page 12 GAO-15-8 Market Research

Agencies’ guidance generally mirrors the FAR in terms of potential 

internal techniques that could be used to conduct market research and 

provides additional means to communicate with industry that are not 

specified in the FAR. For example, while the FAR suggests that 

acquisition staff place a request for information in technical or scientific 

journals or business publications, DOD, DHS, and DOT guidance 

expands upon this suggestion by indicating that requests for information 

could be posted on FedBizOpps. A contracting officer could use such a 

posting to solicit industry response to a questionnaire or obtain industry 

comment on a draft statement of work on behalf of an acquisition team. 

Further, a contracting officer can post a sources sought notice—a notice 

requesting that vendors interested in providing a particular product or 

service identify themselves—on FedBizOpps. DHS guidance notes that 

vendors who respond to the notice usually describe their capabilities or 

similar projects they have conducted, among other things. While DOD 

guidance also recommends these techniques, it also suggests that 

acquisition staff take additional measures to reach vendors that have not 

previously bid on government contracts, such as advertising in business 

publications. In addition, DOD guidance recommends attending trade 

shows and conferences as a good source of general information about an 

industry and DHS guidance identifies these events as places to meet 

industry leaders and vendors.

To promote industry outreach, each agency in our review has developed 

guidance, known as vendor communication plans, designed to facilitate 

interaction between acquisition staff and vendors. Agencies’ actions were 

consistent with an OMB initiative intended to encourage acquisition staff 

to have productive interactions with industry partners during the 

acquisition process.24 In a February 2, 2011 memorandum, OMB stated 

that such outreach is important so that the government has a clear 

understanding of the marketplace and can award a contract for an 

effective solution at a reasonable price.25

 24FAA published its vendor communication plan in July 2009, prior to the OMB initiative. 

The memorandum further states 

that acquisition staff were not taking full advantage of flexibilities offered 

in the FAR because of their concern that vendors could misinterpret the 

discussions as obligating the government to conduct business with them 

and that agencies must remove unnecessary barriers to reasonable 

25See OMB, “Myth-Busting” Memorandum (Washington, D.C.: Feb. 2, 2011) and OMB, 

“Myth-Busting 2” Memorandum (Washington, D.C.: May 7, 2012).
Page 13 GAO-15-8 Market Research

communication with industry. DOD and DHS guidance cite the 

importance of clear and frequent communication between government 

and industry because of benefits for improved acquisition outcomes, 

including opening the door for more small business participation.

While agencies’ guidance identifies a broad array of market research 

techniques, the guidance also notes that the extent or type of market 

research will vary, depending on factors including urgency, estimated 

dollar value, complexity, and past experience. For example, DHS 

guidance notes that several methods of obtaining information from 

industry, such as sponsoring presolicitation conferences to discuss 

industry comments on proposed solicitations, are conducted more 

typically for complex requirements. DOD guidance recognizes the 

importance of market research on lower dollar procurements, noting that 

DOD awards a multitude of lower-dollar contracts for new products or 

services and that the goals of market research to understand the 

commercial market remain the same for these procurements. DOD and 

DOT guidance suggests that acquisition staff weigh the administrative 

cost of conducting market research to the potential benefits. Similarly, 

DHS guidance suggests that the acquisition team solicit the contracting 

officer’s advice to avoid requesting more than the minimum information 

necessary from potential sources when conducting market research. FAA 

guidance suggests that market research may range from a telephone call 

to formal market surveys or solicitations requesting information.

All four agencies require that market research be clearly documented 

since it can inform current and future procurements, but the guidance 

varies in terms of the elements that are to be included in the 

documentation. The FAR requires that for more complex and higher dollar 

procurements, acquisition personnel prepare written acquisition plans that 

include a description of prospective sources and address the extent and 

results of market research and the impact of these findings on various 

elements of the plan.26

 26FAR § 7.105(b)(1). FAR § 7.103(e) directs that agency heads determine criteria and 

thresholds under which increasingly greater detail and formality in the planning process is 

required. 

Consistent with the FAR, all of the agencies in our 

review have guidance regarding acquisition planning for procurements 

designated as more complex or higher value. At DOD, DHS, and DOT, 

written acquisition plans are typically required for higher valued 

Selected Agencies 

Require Market Research 

Be Documented, but Vary 

in the Amount of Specific 

Information Required
Page 14 GAO-15-8 Market Research

acquisitions. For example, at DHS, these plans are typically required for 

acquisitions of $10 million and above and, at DOT, written acquisition 

plans are generally required for procurements greater than $20 million.

FAA has similar requirements for acquisition plans for most procurements 

greater than $25,000. In addition, in most cases where a product or 

service is to be acquired on a sole-source basis, the FAR requires that 

contracting officers prepare a written justification, also known as a 

justification for other than full and open competition, which is to include a 

description of the market research conducted or the reason that market 

research was not conducted as a part of justifying that a contract be solesourced.27

Beyond the market research information required as part of acquisition 

plans for more complex, higher dollar value procurements, or as part of 

the justification and approval for sole-source procurements, we found that 

the specific type of market research information that must be documented 

for all procurements, including contracts of lower value, varies 

considerably by agency. Only DHS required, as of January 2014, that 

specific elements—such as who conducted the market research, the 

methods used, and the outcome and impact of the market research—be 

documented. In contrast, DOD, DOT, and FAA do not require that specific 

elements be recorded consistently, although DOD and FAA guidance 

contain recommendations on elements that could be recorded (see figure 

2).

The agencies in our review all have guidance regarding 

justifications for sole-source contracts, and DHS and FAA’s guidance 

specifically address the requirement to describe the market research in 

support of the sole-source award.

 27FAR § 6.303-2(b)(8). The FAR outlines similar requirements for orders and blanket 

purchase agreements above the simplified acquisition threshold established under the 

federal supply schedules without using competitive procedures. See FAR § 8.405-

6(c)(2)(vi).
Page 15 GAO-15-8 Market Research

Figure 2: Required and Recommended Market Research Elements as of July 2014

a

The simplified acquisition threshold is generally $150,000.

DOD and FAA market research guidance recommends, but does not 

require, documenting elements similar to the ones DHS requires be 

documented. In addition, DOD guidance recommends documenting the 

timeframes during which the market research was conducted, a 

description of commercial business practices, and related cost and price 

factors. DOD, DHS, and FAA provide templates or sample memorandums 

for the contract file that contain placeholders for recommended 

information.28

DOD, DHS, and FAA have taken steps to enhance the documentation of 

market research information over the past few years. For example:

DOT market research guidance does not specify elements 

to be documented, and notes that the type and amount of information to 

be kept should be based on how it may be used in the future and whether 

the documentation is for a one-time, unique, or recurring requirement.

 28DOD’s template applies specifically to services acquisitions.
Page 16 GAO-15-8 Market Research

• In April 2012, DOD officials issued a template, including 

recommended information, for preparing market research reports for 

services acquisitions. The template was prepared by a working group 

that identified best practices for conducting and documenting market 

research to allow for more effective collection and sharing of market 

research across DOD. The first part of the template is for recording 

basic information, such as a description of vendor capabilities and 

small business opportunities. The second part of the template is 

targeted toward more complex high-dollar value procurements and 

requires more detailed information about the commercial market, such 

as a description of the demand for the service and an assessment of 

fair and reasonable prices. DOD officials reported to us that they are 

considering whether use of the template should be mandatory.

• In October 2012, FAA issued its sample Market Research 

Memorandum to the File with recommended elements to record, and 

in April 2013, FAA first required the use of written acquisition plans. 

The acquisition plan template for acquisitions above the simplified 

acquisition threshold instructs that the results of market research be 

recorded, as well as the size and status of each source, and a 

competition determination—for example, whether the work should be 

set aside for small businesses.

• DHS had previously included in guidance that minimum elements be 

documented. In January 2014 DHS incorporated these required 

elements into the Department of Homeland Security Acquisition 

Manual. According to DHS officials, by doing so, the agency elevated 

the importance of including these elements in market research 

reports.

Based on our analysis of market research elements identified in DOD, 

DHS, and FAA policy, guidance, or templates, we identified and 

discussed with agencies’ officials four basic market research elements, 

which, if recorded, would allow those not connected with the research to 

understand how the acquisition team collected and analyzed information 

about capabilities within the market to satisfy agency needs. These four 

market research elements include (1) the methods used, (2) the 

timeframes when staff used them, (3) an analysis of the capabilities of 

potential sources, and (4) a conclusion based on this analysis. DOD, 

DHS, and FAA market research policies, guidance, or templates included 

at least three of the four basic elements. For example, at DHS, three of 

these elements were included in the Department of Homeland Security 

Acquisition Manual and the fourth element, timeframes, was included in 

DHS’s market research template. However, DOT’s market research 

guidance did not include any specific elements. Internal control standards 

state that control activities, such as policies and procedures, help ensure 
Page 17 GAO-15-8 Market Research

that management directives are carried out and actions are taken to 

address risks.29 Requiring that specific market research elements be 

documented in contract files would help ensure that documentation is 

readily available to inform current and future procurements.

We found that all 28 contracts we reviewed included some evidence of 

market research, but the market research on higher dollar value 

contracts—those valued at $10 million or more—tended to be more 

robust and appeared to help promote competition. Agencies did not take 

advantage of many available market research techniques on lower dollar 

value contracts, and as a result may have missed opportunities to 

promote competition. In 10 of the 12 higher dollar contracts we reviewed, 

agency officials conducted outreach to vendors through issuance of 

requests for information, draft requests for proposals, or other techniques. 

In some cases, this approach resulted in the agency modifying or 

clarifying its requirements to encourage competition, and all but one of 

the higher dollar contracts that conducted some type of formal outreach to 

industry received more than one offer. In contrast, in only 4 of the 16 

lower dollar contracts did DOD, DHS, and DOT officials conduct formal 

outreach to industry, instead often relying on issuance of a notice that the 

agency intended to award a contract on a sole-source basis or on a 

review of the government’s acquisition history. In several cases, DOD and 

DHS officials relied on market research that appeared to be incomplete or 

outdated. Overall, we identified limitations in the market research 

supporting seven lower dollar value contracts, all of which were solesourced or received only one offer. Similarly, while all 28 contracts we 

reviewed contained evidence of market research, agency officials often 

did not document one or more of the four basic market research elements 

which we identified based on our review of agencies’ guidance, potentially 

limiting the ability to use this market research to inform future 

procurements. We also found that agencies’ officials used market 

research to inform price reasonableness determinations in most of the 

contracts we reviewed, though other techniques were also frequently 

used to inform pricing determinations.

 29GAO, Internal Control: Standards for Internal Control in the Federal Government,

GAO/AIMD-00-21.3.1 (Washington, D.C.: November, 1999).

Selected Agencies 

May Have Missed 

Opportunities to 

Promote Competition 

and Inform Future 

Procurements on 

Lower Dollar 

Contracts
Page 18 GAO-15-8 Market Research

We found that agencies’ market research on the higher dollar value 

contracts generally involved more communication with industry and these 

contracts were more often awarded on a competitive basis than were the 

lower dollar value contracts we reviewed (see figure 3).

Figure 3: Market Research Techniques and Competition Results on 28 Contracts 

GAO Reviewed

Note: For the purposes of this analysis, we defined communication with industry to include attending 

industry trade shows or conducting site visits, contacting multiple potential vendors and using their 

feedback to update or clarify the requirement, or publishing formal requests for information, sources 

sought notices, or draft solicitations in FedBizOpps.

In particular, we found that for higher dollar contracts, agencies’ officials 

made more extensive use of techniques involving communication with 

industry, such as issuing requests for information and draft requests for 

proposals, and holding conferences with vendors—using these types of 

techniques on 10 of the 12 higher dollar value contracts we reviewed. 

These methods allowed agencies’ officials to gather vendor feedback and 

collect information that could be used to refine requirements and inform 

competition determinations. The lower dollar contracts we reviewed relied 

more extensively on internal sources of information, such as the 

knowledge of program officials, examinations of acquisition history, or on 

the issuance of notices of intent to sole-source as the main sources of 

Market Research on 

Higher Dollar Value 

Contracts Involved More 

Communication with 

Industry and Contributed 

to Competition
Page 19 GAO-15-8 Market Research

market research, rather than on formal outreach to industry.30

The following examples highlight some market research techniques used 

by agencies’ officials on higher dollar value contracts, conclusions 

reached based on the market research, and competition outcomes:

Specifically, 

while market research on 4 of the 16 lower dollar contracts we reviewed 

involved outreach to industry, there was no outreach to industry on the 

other 12 contracts reviewed. The FAR states that agencies are 

encouraged to promote early exchanges of information about future 

acquisitions to, among other things, improve the understanding of the 

government’s requirement and industry capabilities.

• The FAA awarded a $2 billion contract for data communication 

integrated services after conducting 14 formal requests for information 

and other outreach to potential vendors over a 4-year period. The 

contracting staff used the information gathered from industry to help 

develop the final requirement. FAA received offers from three vendors 

it had identified as likely to make offers based on its market research 

efforts.

• Similarly, on an $87 million DHS contract for guard services, the 

contracting specialist identified thousands of potential contractors 

through a database, narrowed this number to 172 potential vendors 

by cross referencing the vendor information with online information 

about vendors with existing government-wide contracts, issued a 

sources sought notice, evaluated 26 responses to the notice, and 

ultimately concluded that there were enough sources capable of 

meeting the need to allow for full and open competition. Eighteen 

vendors made offers on the contract.

• In a $72 million DHS acquisition for program management and 

logistics support, a total of 31 contractors responded to either a 

request for information posted in 2009 and/or a subsequent one 

posted in 2011. The feedback obtained through the requests for 

information led to the conclusion that the acquisition strategy should 

be revised to address industry questions, comments, and concerns, 

including issues with funding and performance related to the contract 

structure. Agency officials therefore issued a sole-source bridge 

contract, in part so that they could revise the requirement. 

Additionally, the market research report for this contract stated that 

 30FAR Part 5.2 generally requires agencies to publish notice on FedBizOpps of proposed 

contract actions. 
Page 20 GAO-15-8 Market Research

while all 31 contractors responding to the requests for information 

might not make offers or be capable of fulfilling the requirement, the 

information gathered from the responses gave the agency insight into 

the capabilities of the marketplace, and led to the conclusion that 

there would be ample qualified vendors in the market to meet the 

requirements of a subsequent contract. According to an agency 

official, the award of the follow-on contract is now in process—being 

competed among certain small business set aside vendors—and the 

agency has received multiple offers. The offers are currently being 

evaluated, and DHS officials anticipate awarding the contract around 

the close of fiscal year 2014.

Overall, our work found the market research, and in particular, industry 

outreach efforts, appeared to contribute to the degree of competition 

achieved on the higher dollar contracts we reviewed. For example, 9 of 

the 12 higher dollar contracts we reviewed received more than one offer; 

and in all but one of these cases, agencies’ officials conducted some type 

of formal outreach efforts to industry.

While the higher dollar value contracts tended to be competed and most 

involved outreach with industry, we found additional market research 

actions could have potentially promoted competition on a 3-year, $210 

million DLA contract for tax-free fuel in Italy awarded in 2011. In this case, 

DLA enables U.S. military personnel to purchase fuel on a tax-free basis 

while stationed there. To do so, DLA issued a solicitation that required 

potential offerors, among other things, to (1) have at least 1,000 service 

stations in Italy and (2) be able to accept printed coupons that allowed 

military personnel to buy the fuel on a tax-free basis. The market research 

performed by program officials consisted of a list of all of the fuel 

companies operating in Italy; however, contracting officials confirmed that 

only two of the nine companies on the list were likely to be able to meet 

the requirement of 1,000 gas stations included in the solicitation. Both of 

these companies were incumbents on the prior contract. However, 

contracting officials stated that one of the two companies, which was an 

incumbent, did not submit an offer because the continued use of printed 

coupons was too cumbersome for them. After receiving a single offer, the 

contracting officer asked the program office whether it was feasible to use 

a credit card program or a combination of printed coupons and credit 

cards to meet the need, as agency officials stated that DLA has done in 

other countries, but the requirement was left unchanged and the contract 

was awarded to the single vendor that submitted an offer. Contracting 

officials told us that as of May 2014, they were considering developing a 

business case analysis to assess the costs and benefits of switching to a 
Page 21 GAO-15-8 Market Research

credit card program. DLA officials told us that formally analyzing 

alternative approaches and changing from a coupon to a credit card 

program would need to be coordinated through the Italian government 

since tax-free privileges are a benefit provided by the Italian government.

Lower dollar value contracts we selected were less likely to be competed 

than higher dollar value contracts—while 6 of the 16 lower dollar value 

contracts were competed, 3 of those received only one offer, and the 

other 10 contracts were sole-sourced. As noted previously, market 

research is to be used to promote and provide for full and open 

competition or, when not required, to obtain competition to the maximum 

extent practicable. Even in situations when agency officials anticipate 

awarding a sole-source contract, the contracting officer is generally

required to identify actions, if any, the agency may take to remove or 

overcome any barriers to competition for future acquisitions of the 

supplies or services required. Overall, we identified limitations in the 

market research supporting seven lower dollar value contracts awarded 

by DOD and DHS, all of which were sole-sourced or received only one 

offer. As a result, DOD and DHS officials may have missed opportunities 

to promote competition. In several cases, agency officials relied on 

market research that appeared to be incomplete or outdated. Examples of 

these cases are highlighted below:

• Market research on a $1.6 million DHS contract to rent parking 

spaces near a DHS building located in Arlington, Virginia, cited 

multiple potential vendors through a review of prior acquisition history, 

a government database, and a DHS source list, but the market 

research did not include any formal outreach to industry. The market 

research, conducted by a program official, identified three potential 

parking facilities within one block of the DHS building but did not 

assess whether potential vendors could provide direct elevator access 

to the building, a key requirement specifically included in the 

solicitation. The agency received only one offer from a parking facility 

adjacent to the building. Subsequently, an agency attorney who 

reviewed the scope of work wrote that the requirements seemed 

unusually narrow and that only one vendor would likely be able to 

provide a parking garage with an elevator that connected to the office 

building. We found no evidence that DHS used market research to 

reassess whether DHS’s requirement could be modified, and as a 

result, the agency may have missed opportunities to receive more 

than one offer.

Market Research on 

Lower Dollar Value 

Contracts Was Often 

Limited and May Have 

Missed Opportunities to 

Promote Competition
Page 22 GAO-15-8 Market Research

• In a $2 million Army contract for flight simulator training services 

receiving only one offer, the primary market research was a sources 

sought notice posted for 10 days on FedBizOpps for which a 

response was only received from the incumbent vendor. Further, over 

a 10-year procurement history for these services, market research 

consisted of two sources sought notices—the one already discussed 

and one issued in 2006. While the contracting officer doubted whether 

any other vendors had the capability to fulfill this particular 

requirement, the contracting officer acknowledged more market 

research could have been done to ensure this conclusion was 

accurate, such as outreach to other potential vendors who provide 

flight simulator services.

• Despite predating the formation of DHS and agency officials’

acknowledgement of technological advances, the market research for 

a $627,000 DHS contract for satellite airtime needed to receive global 

positioning data from tracking devices included in CBP aircraft had not 

been updated since 1999. According to agency officials, the satellite 

airtime was tied to the use of those particular tracking devices. 

Agency officials indicated they reviewed the procurement’s acquisition 

history and issued a notice of intent to sole-source, though the notice 

was issued after the agency had already awarded the contract. Since 

the government was required to use the same vendor for both the 

airtime and the tracking devices, contracting officials deemed a 

vendor who responded to the notice ineligible. Contracting officials we 

spoke with acknowledged that the market research was limited and 

more needed to be done to assess whether there were viable 

alternatives to the tracking devices and its proprietary satellite airtime.

In two cases, while a lack of technical data rights may have contributed, 

in part, to challenges competing a contract, we nevertheless found 

limitations in the market research conducted to inform the acquisition 

approach.31

 31With regards to the issue of a lack of technical data rights, DLA officials noted that DLA 

is responsible for sustainment of weapons systems and does not have data rights for 

many items they procure. DLA officials stated that if potential alternate sources are not 

found during market research prior to issuing a solicitation, then DLA Directive clause 

52.217-9002 “Conditions for Evaluation of Offers for Part Numbered Items” may be 

included in the solicitation. This clause may be used in negotiated acquisitions of 

replacement parts, components, and assemblies which are identified only by the name of 

the approved source, a part number, and a brief description, and the clause provides, 

among other things, that vendors can offer an alternate product, which could increase 

competition. DLA Directive § §17.7501(b)(3)(i); 52.217-9002.

For example:
Page 23 GAO-15-8 Market Research

• In a $589,000, sole-source DLA contract for actuators, the market 

research consisted of a presolicitation notice that was issued 2 

months before the contract was signed, an examination of prior 

acquisition history with the incumbent, and a market survey, which 

was sent only to the incumbent, who did not fill it out. Although 

contracting officials told us that the solicitation was published on 

DLA’s site for contracting opportunities, they also stated that there 

were few options for conducting market research because the product 

was designed to adhere to specific government requirements. In 

addition, officials stated that they typically rely on a program office to 

provide information about whether a vendor is an approved source, 

especially in cases where the government does not own the data 

rights. Contracting officials also told us that this vendor had a history 

of non-responsiveness and they had not expected to gather any 

information from the market survey.

• In a $694,000 DLA contract for controller monitors, which are one part 

in a piece of equipment used to provide oxygen to crew members in 

an aircraft, DLA faced a similar challenge because it did not own the 

data rights. Our contract review revealed that contracting officials had 

identified two sources but determined that one of the two sources was 

not viable because it was a reseller that would obtain the item from 

the manufacturer; contracting officials told us that they did not pursue 

this source because they thought that the vendor would likely charge 

a higher price after obtaining it from the manufacturer. The other main 

source of market research cited in the contract’s justification to solesource was issuance of a notice of intent to sole-source, where no 

other vendors responded.

While market research on the lower dollar value contracts we reviewed 

was often limited, this was not always the case, even in situations where 

the contract was not competed. For example, our work found that the 

market research on two lower dollar value, sole-source contracts included 

in-depth analysis of potential sources found in the market, identification of 

reasons why the vendor was uniquely qualified to meet the need, and the 

tradeoffs that would need to be considered to compete the requirement. 

In one procurement involving a $1.1 million Army contract for armored 

windows used on mine clearance vehicles, the market research assessed 

three vendors and analyzed tradeoffs and costs given that the 

government did not own the data rights for the windows currently used. 

Specifically, the market research explained how the contracting officer 

used Internet searches to identify specific vendors, listed the vendors and 

websites accessed, and used this information to analyze tradeoffs 

associated with these potential sources. The market research also 

referenced attempts to gauge industry interest by issuing a sources 
Page 24 GAO-15-8 Market Research

sought notice over 6 months prior to issuing an intent to sole-source 

notice. The analysis quantified the time and cost associated with reverse 

engineering the product to produce a set of government-owned data 

rights, which could be used to qualify new potential sources. The 

justification and approval also noted that an additional vendor had 

expressed interest in becoming a qualified source but the agency 

concluded that the vendor was unsuitable for the current procurement 

due to the significant amount of time needed to develop a data package.

Our review found that all 28 contracts included some evidence of market 

research, but acquisition staff did not consistently document four basic 

elements in the contract file—the methods used, including the timeframes 

when staff used them, an analysis of the capabilities of potential sources, 

and a conclusion based on this analysis—which GAO determined would 

allow those not connected with the research to understand the market 

research conducted.32

 32In the absence of guidance from DOT, we compared the contents of DOD, DHS, and 

FAA guidance to identify the minimum elements which, if recorded in the contract file, 

would allow others, such as reviewers or those procuring similar items in the future, to 

understand the nature of the market research conducted, potential sources, and how it 

was used. 

Overall, 14 of the 28 contracts we reviewed 

included all of these elements in the market research documentation in 

the contract files. However, while agency guidance describes market 

research documentation as useful for current and future acquisition 

decision making, we could not find one or more of the basic elements for 

14 of the 28 contract files we reviewed, with 10 of the 14 contracts being 

ones we categorized as lower value. Nine of these 10 contracts were 

awarded by DOD and DHS (see figure 4).

Basic Market Research 

Elements Were Not 

Consistently Documented, 

Limiting Use for Future 

Procurements
Page 25 GAO-15-8 Market Research

Figure 4: Number of Contracts Whose Documentation Includes or Excludes Basic 

Elements

Overall, 8 of the 12 higher dollar contracts we reviewed contained each of 

the basic elements, including information on potential vendors and 

analyses of their capabilities, information more typically missing from the 

lower dollar value contracts.33

 33In response to GAO’s finding that one of FHWA’s higher dollar contracts did not include 

documentation of all four elements, FHWA officials told us that they considered the market 

research conducted on the $20 million contract for legal advisory services to be extensive, 

noting that as a part of market research the agency reached out to dozens of potential 

sources. The officials acknowledged, however, that better documentation of the analysis 

of the capabilities of these sources would have strengthened the overall market research.

This was true whether the information was 

contained in an acquisition plan, the justification for other than full and 

open competition, or the market research report. For example, for the 

Army’s $28.5 million contract for the procurement of advisory and 

assistance services, the written acquisition plan included the names of 

potential small business vendors who responded to the survey and an 

assessment of their capabilities. In another example, for an FAA 

procurement of a $126.6 million engine generator set program, the 

market research memo recorded the names of each vendor who 

responded to a market survey and an evaluation of their capabilities, 

including whether the vendor had the capacity to meet the requirement 

with in-house resources.
Page 26 GAO-15-8 Market Research

The market research documentation on the lower dollar contracts was 

more likely to be missing at least one element, particularly at DOD and 

DHS, where only 3 of the 12 lower dollar contracts we reviewed included 

documentation of all four elements. In particular, lower dollar value 

contracts were less likely to include information on potential vendors and 

an assessment of their capabilities. For example, the justification for other 

than full and open competition on CBP’s $609,000 sole-source 

procurement for portable receiver devices awarded in September 2012 

lacked information describing the capabilities of other possible vendors 

and the dates on which any market research was conducted. The 

contract specialist explained that the release of funding late in the fiscal 

year sometimes prevents staff from drawing up more complete market 

research documentation. In another example, the acquisition plan for a 

$2.3 million DLA contract for the lease of office copy machines lacked 

information about the capabilities of specific vendors. While the 

acquisition plan concluded that “at least five vendors could supply the 

equipment and associated services,” it did so without identifying the 

market research techniques used or the names of the potential vendors. 

In response to our questions, the contracting office was aware of the 

names of the five vendors, explaining that prior information and expertise 

were relied upon due to the non-complexity of the requirement.

Not fully documenting basic elements of market research limits the 

information and insights that can be carried forward for use with 

subsequent contracts, especially given the potential for staff turnover in 

the acquisition workforce and the possibility that the need for the 

requirements will recur. For example, contracting and/or program staff for 

5 of the 20 selected contracts we reviewed at DOD and DHS advised us 

that the original program or contracting staff were no longer available to 

respond to questions, and in two of these cases current staff could not 

fully respond to our questions. As we previously concluded, documenting 

information is particularly important given the frequent turnover in the 

acquisition workforce.34

 34

Further, according to agency officials, over threequarters of the 20 contracts we selected at DOD and DHS provide for 

requirements that are likely to recur in the future, and therefore, 

adequately documented market research could prove useful in the future. 

As we noted earlier, requiring that these basic elements be documented 

in contract files would be consistent with internal control standards that 

GAO-11-672.
Page 27 GAO-15-8 Market Research

transactions and other significant events need to be clearly documented 

and the documentation should be readily available for examination so as 

to ensure that management directives are carried out.35

The FAR identifies several techniques that can be used to help determine 

that a price is fair and reasonable, including a comparison between 

proposed prices received in response to a solicitation or a comparison 

between proposed prices and the independent government cost 

estimate.36 While not required by the FAR or agency guidance, agencies’

guidance recognizes the usefulness of market research in assessing what 

price would be reasonable for the government to pay for a procurement. 

In addition, OMB has stated that outreach to vendors is important so that 

the government has a clear understanding of the market place and can 

award a contract for an effective solution at a reasonable price.37

We identified the use of a variety of market research techniques in 

determining price reasonableness such as a review of published price 

lists, reviewing historical prices, and techniques involving communication 

with industry. While using market research to help inform the price 

reasonableness determination tended not to involve communication with 

industry, 5 contracts we reviewed did cite market research techniques 

that involved communication with industry. The techniques involving 

communication with industry included obtaining prices through requests 

for information posted on FedBizOpps, vendor quotes, and government 

requests. Two of the five were higher dollar contracts—one was 

competed and received multiple offers and the other was sole-sourced—

where the contracting officer used pricing information received from 

industry in response to government requests for information to determine 

price reasonableness. For two of the three lower dollar contracts, the 

market research technique used was to obtain quotes from other vendors 

Contracting officers cited one or more market research techniques as 

contributing to their determination of a fair and reasonable price in 21 of 

the 28 contracts we reviewed. The market research for 5 of these 

contracts involved communication with industry.

 35GAO/AIMD-00-21.3.1.

36The contracting officer may use an independent government cost estimate to help 

establish the reasonableness of contractors’ costs or prices.

37See OMB, “Myth-Busting” Memorandum (Washington, D.C.: Feb. 2, 2011).

Market Research Helped 

Inform Price 

Reasonableness 

Determinations in Most of 

the Contracts Reviewed
Page 28 GAO-15-8 Market Research

to compare to the proposal received—both of these were competed 

contracts where only one offer was received.

In 5 of the 21 cases where contracting officers cited ways that market 

research helped in the determination of fair and reasonable prices, 

contracting officers also cited how this pricing information helped the 

government to negotiate a price lower than what was originally proposed 

by the vendor. For example, in the $210 million DLA contract to provide 

fuel in Italy, based on our review of contract documentation, the 

contracting officer reviewed pricing information from the country’s 

marketplace through published pricelists and prior contract prices, and 

used this information to set pricing goals for negotiations with the vendor. 

According to the contract file documentation, the government was able to 

negotiate a lower price for certain types of fuel than what the contractor 

had originally proposed even though only one offer was received. As we 

noted previously, however, DLA did not assess whether its requirement to 

use a printed coupon system could be modified to consider the use of a 

credit card system, which may have enabled DLA to obtain the benefits of 

market forces to help negotiate even lower prices.

In contrast, in one case in which the contracting officer cited market 

research as supporting a fair and reasonable price determination, we 

found that opportunities to use additional market research or other price 

reasonableness techniques may have been missed. For a 3-year, $1.5 

million sole-source contract awarded by DHS for membership services to 

an organization that oversees the creation and use of business 

guidelines, agency officials were unable to provide documentation based 

on market research or other techniques to fully support their price 

reasonableness decision. The justification and approval stated that the 

contracting officer had determined the anticipated prices to be fair and 

reasonable based on price comparisons to the prior contract, and by 

comparing a published price list against the government’s independent 

government cost estimate. However, DHS officials admitted that the 

scope of work for the previous contract was different from the scope of 

work for the current contract and that the contracts could not be fully 

compared. In addition, we found that the price of annual membership 

services under the current contract and as cited in its independent 

government cost estimate was more than 10 times higher than the price 
Page 29 GAO-15-8 Market Research

for full membership services as listed on the published price list.38

For the 7 contracts that did not use market research techniques to 

determine price reasonableness, the contracting officers indicated that 

they used techniques such as comparing proposed prices to the 

independent government cost estimate and comparing prices among 

proposals received. For example, most of the competitive contracts we 

reviewed that received multiple offers cited the comparison of offers 

received as contributing to their determination of a fair and reasonable 

price. In addition, a contracting officer is required to obtain certified cost 

or pricing data from the contractor in certain instances, including for 

negotiated contracts above $700,000, unless an exception applies, such 

as obtaining adequate price competition or acquisitions of a commercial 

item.

Subsequently, a program official provided us with a high level breakdown 

of the costs that had been provided to the program office by the vendor 

prior to contract award but advised us that they had no additional 

documentation to support the price reasonableness determination within 

the program office.

39 Nearly all of the noncompeted contracts we reviewed were either 

below the $700,000 threshold for which certified cost or pricing data may 

be required, or were for commercial items, and therefore did not obtain 

certified cost and pricing data. In the two cases in which contracting 

officers were required to obtain certified cost and pricing data, we found 

acquisition officials did so.

Federal regulations and the agency guidance we reviewed highlighted the 

need to conduct and document market research commensurate with the 

proposed acquisitions’ dollar value and complexity. We found evidence of 

market research in all 28 contracts we reviewed. Similarly, we often found 

that acquisition officials conducted more robust market research on 

higher dollar value contracts in particular by communicating with industry 

about their requirements and needs, such as through the use of requests 

 38A program official told us that the published price list reflected a basic membership price 

and the total contract price included the price for additional membership services outlined 

in the statement of work, such as access to international standards, workshops convened 

by a panel focused on the development and adoption of standards critical to homeland 

security, and a database. However, there was no documentation to support the price 

reasonableness of these additional services included in the contract file.

39FAR §15.403-4. 

Conclusions
Page 30 GAO-15-8 Market Research

for information. In turn, this market research appeared to contribute to 

higher degrees of competition for higher value contracts. Our findings 

also suggest, however, that agencies may be missing opportunities to 

promote competition and inform future acquisitions for lower dollar 

acquisitions. In this regard, we found DOD and DHS acquisition officials 

often relied on internal sources of information or simply notified potential 

vendors that they intended to award contracts on a sole-source basis 

rather than gauging whether the marketplace could offer an alternative, 

competitive solution. Even in situations where the government anticipates 

a sole-source award, market research is a tool that is required to be used 

to promote competition to the maximum extent practicable, and agencies 

generally must identify actions, if any, they may take to remove or 

overcome barriers to competition for future acquisitions of the supplies or 

services required. We also found instances in which the market research 

appeared to be incomplete or outdated.

Further, we found that acquisition officials omitted one or more of four 

basic elements of market research which GAO identified as necessary to 

enable others to understand the research—the methods used, the 

timeframes when it was conducted, an analysis of vendor capabilities, 

and a conclusion based on this analysis—in 14 of the 28 contracts we 

reviewed. These documentation shortfalls were more often, though not 

exclusively, found in lower value contracts. Despite DOD and DHS having 

guidance that either requires or recommends that specific elements be 

documented, contracts from these agencies accounted for all but one of 

the 10 lower value contracts missing one or more of the elements. While 

DOT documented these four elements in most of the contract files we 

reviewed, DOT’s market research guidance does not address whether 

these four basic elements should be documented. As a result, DOT is at 

increased risk that it will not document the basic information needed to 

help inform current and future procurements. Federal internal control 

standards state that transactions and other significant events need to be 

clearly documented and the documentation should be readily available for 

examination, so as to ensure management directives are carried out. 

Moreover, given the recurring nature of the government’s requirements 

covered in the contracts we reviewed and the staff turnover we observed 

during the course of our work, not clearly documenting such fundamental 

information hinders the use of market research to inform future 

acquisitions.
Page 31 GAO-15-8 Market Research

To help ensure that key market research information is available for

current and future use, we recommend that the Secretary of 

Transportation update its market research guidance to specify, at a 

minimum, that four basic elements—the market research methods used, 

the timeframes when staff used them, an analysis of the capabilities of 

potential sources, and a conclusion based on this analysis—be 

documented.

To help promote competition, inform future acquisitions, and encourage 

the use of timely and complete market research, we recommend that the 

Secretaries of Defense and Homeland Security take action to ensure their 

acquisition personnel clearly document the basic elements of the market 

research that was conducted. More specifically, documentation should, at 

a minimum, include the market research methods used, the timeframes

when staff used them, an analysis of the capabilities of potential sources, 

and a conclusion based on this analysis.

We provided a draft of this report to DOD, DHS, and DOT for comment. 

All three agencies concurred with our recommendations. The agencies’ 

comments are summarized below. Written comments from DOD, DHS, 

and DOT are reproduced in appendixes II, III, and IV respectively. DHS 

and DOT provided technical comments which we incorporated into the 

report as appropriate.

DOD agreed with the recommendation that it take action to ensure its 

acquisition personnel clearly document the basic elements of market 

research conducted, but did not identify specific actions it intends to take. 

DOD noted that it recently issued a memorandum highlighting the need 

for effective market research to increase competition.

40

DHS also agreed with the recommendation that it take action to ensure its 

acquisition personnel clearly document the basic elements of market 

research conducted. DHS stated that its Office of the Chief Procurement 

For example, the 

memorandum notes that contracting officers will be required to use 

requests for information or sources sought notices for certain 

procurements where a non-competitive contract is contemplated. 

 40DOD, Office of the Under Secretary for Acquisition, Technology, and Logistics, Actions 

to Improve Department of Defense Competition (Washington, D.C.: Aug. 21, 2014).

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 32 GAO-15-8 Market Research

Officer will update procedures in the Homeland Security Acquisition 

Manual and its market research guide to clarify that market research 

reports should include, at a minimum, the four basic elements. Given that 

we found that several DHS contract files we reviewed did not include 

documentation of elements already required by DHS, it will be important 

for DHS to ensure its contracting personnel follow its guidance. 

DOT agreed with our recommendation that it update its market research 

guidance to identify documentation of the four basic elements, but did not 

elaborate on specific actions it intends to take. DOT stated that it 

recognizes the important role market research plays in developing sound 

acquisition strategies, promoting competition, and informing price 

reasonableness. DOT noted that its market research guidance is 

consistent with the requirements of the FAR, and noted that the agency 

continues to seek opportunities and incorporate best practices to further 

strengthen departmental guidance. Given the importance of written 

guidance in helping to ensure that management directives are 

implemented, we continue to encourage DOT to update its guidance to 

require documentation of the four basic elements on a timely basis.

We are sending copies of this report to the Secretary of Defense, the 

Secretary of Homeland Security, the Secretary of Transportation, 

appropriate congressional committees, and other interested parties. This 

report will also be available at no charge on GAO’s website at 

http://www.gao.gov.

If you or your staff have any questions concerning this report, please 

contact me at (202) 512-4841 or by e-mail at dinapolit@gao.gov. Contact 

points for our Offices of Congressional Relations and Public Affairs may 

be found on the last page of this report. Key contributors to this report are 

listed in appendix V.

Timothy J. DiNapoli

Director

Acquisition and Sourcing Management
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-15-8 Market Research

Our objectives were to assess (1) selected agencies’ guidance and policy 

on market research and (2) how selected agencies conducted market 

research on selected procurements. Market research serves several 

purposes, including identifying sources capable of meeting the need, 

promoting competition, identifying whether commercial items can meet 

the government’s needs, and identifying whether small businesses are 

capable of meeting the requirement. For the purposes of our review, we 

focused our work on how market research informed the competition 

strategy and the contracting officer’s analysis of price reasonableness. 

We did not assess how market research informed the small business 

determination or how it informed the commerciality decision given GAO 

has a prior body of work that focuses on these issues.1

To assess agency guidance and policy on market research, we reviewed 

government-wide regulations and policy, such as the Federal Acquisition 

Regulation (FAR), including FAR Subpart 7.1—Acquisition Plans and 

FAR Part 10—Market Research, and Office of Management and Budget 

(OMB) memorandums related to market research, such as OMB’s Office 

of Federal Procurement Policy’s memorandum entitled, “Myth-Busting”: 

Addressing Misconceptions to Improve Communication with Industry 

During the Acquisition Process. To assess specific agency guidance and 

policy and to illustrate how market research is performed at agencies of 

various sizes and that procure a range of products and services, we 

selected three departments for our review—the Departments of Defense 

(DOD), Homeland Security (DHS) and Transportation (DOT). We 

selected these departments based on their level of fiscal year 2012 

contract obligations—the most recent fiscal year of information available 

when we started our review—and on the mix of products and services 

procured. Within each department, we selected two components for 

further review—DOD’s Department of the Army and Defense Logistics 

Agency (DLA); DHS’s Office of Procurement Operations (OPO)2

 1

For GAO’s recent work on commercial item determinations, see GAO, Federal 

Contracting: Commercial Item Test Program Beneficial, but Actions Needed to Mitigate 

Potential Risks,

and U.S. 

Customs and Border Protection (CBP); and DOT’s Federal Aviation 

GAO-14-178 (Washington D.C.: Feb. 4, 2014). For GAO’s recent work on 

small business contracting, see GAO, Small Business Contracting: Updated Guidance 

and Reporting Needed for Consolidated Contracts, GAO-14-36 (Washington D.C.: Nov. 

26, 2013).

2

For the purposes of this report, we considered DHS’s Office of Procurement Operations 

to be a component.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-15-8 Market Research

Administration (FAA) and Federal Highway Administration (FHWA). In 

general, we selected the components with the largest fiscal year 2012

obligations based on the Federal Procurement Data System—Next 

Generation (FPDS-NG). For each department and component, as 

applicable, we reviewed guidance and policy related to market research, 

including agency supplements to the FAR, market research guides and 

templates, acquisition handbooks, and policy memorandums that 

reference market research, such as DOD’s Better Buying Power policy 

memorandums. Key agency guidance reviewed included DOD’s Defense 

Standardization Program, Market Research: Gathering Information about 

Commercial Products and Services, SD-5; DHS’s Market Research 

Guide; DOT’s Market Research Guide, Acquisition Policy DOT Dash 

2010-11; and FAA’s Procurement Guidance T3.2.1.2 - Market Analysis.3

The FAR and DOT acquisition regulation do not apply to FAA acquisitions 

so we analyzed FAA’s policy and guidance separately from DOT.4

To assess how agencies conducted market research on selected 

procurements, we selected and reviewed a nongeneralizable sample of 

28 contracts. For each contract, we reviewed contract documents related 

to market research, including market research reports, acquisition plans, 

justifications and approvals for sole-source awards, price negotiation 

memorandums and independent government cost estimates. We 

analyzed these documents to identify market research methods, analysis, 

and results used to inform the competition strategy and to inform the price 

reasonableness determination. To identify information that may not have 

been included or been self-explanatory based on our review of the 

contract files, we obtained additional information from agency officials. 

Our inquiries largely focused on identifying market research techniques 

that agency officials may have used but were not reflected in the contract 

We did 

not include agency training materials as guidance for the purposes of our 

analyses. Further, we interviewed senior acquisition officials at each 

department to develop a better understanding of agency policies, 

guidance, and initiatives related to market research.

 3

While this review focused on guidance applicable across each department and 

separately for FAA, FHWA noted its Acquisition Customer Service Guide contains 

additional information on market research techniques.

4

For the purposes of this report, we use the term agency policy and guidance to refer to 

that issued by DOD, DHS, DOT, as well as FAA. The FAR does not apply to FAA 

acquisitions pursuant to the Department of Transportation and Related Agencies 

Appropriations Act, 1996. Pub. L. No. 104-50, § 348 (1995).
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-15-8 Market Research

file, as well as obtaining further explanations of any analyses they may 

have performed. We also analyzed contract documentation to determine 

whether these documents included four basic elements we identified 

based on our review of agency policy and guidance, which, if recorded, 

would allow those not connected with the market research to obtain at 

least a basic understanding of how the acquisition team collected and 

analyzed information about market capabilities. We also identified these 

elements because they focused on collection and analysis of information, 

consistent with the FAR’s definition of market research.5

To identify contracts for our review, we used FPDS-NG to select a 

nongeneralizable sample of 30 contracts awarded in fiscal year 2012 from 

the six components within DOD, DHS, and DOT. As our review did not 

focus on how market research informed the small business set-aside 

determination or the commercial item determination, we excluded 

contracts set aside for small businesses and contracts for research, 

development, test, and evaluation. To increase the comparability of 

contracts across agencies, we excluded weapons systems contracts, as 

they are unique to DOD. We also excluded contracts with no fiscal year 

2012 obligations and contracts valued at less than $500,000, selecting 

this threshold as the contracts above this threshold represented more 

than 92 percent of contract dollars awarded in fiscal year 2012 at each 

component reviewed.

The four 

elements included the market research methods used, including the 

timeframes when acquisition staff used them, an analysis of the 

capabilities of potential sources, and a conclusion based on this analysis.

Within each selected agency component, we created randomized lists of 

the remaining fiscal year 2012 contracts within two strata—(1) contracts 

valued at more than $10 million and (2) contracts valued between 

$500,000 and $10 million. We selected two contracts from the first 

stratum and three from the second stratum (five per component) from the 

randomized lists for each component. Whereas the higher dollar stratum 

represented the greatest portion of contract dollars awarded in fiscal year 

2012 within each component—ranging between 79 percent and 98 

percent of dollars—the lower dollar stratum represented a larger portion 

of contract actions awarded that year. Within each stratum, we selected 

 5

FAR § 2.101 defines market research as the process used to collect and analyze data 

about capabilities in the market that could satisfy an agency’s procurement needs. 
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-15-8 Market Research

the contracts starting from the top of the randomized lists but applying 

criteria to ensure, to the extent possible, that our selected contracts within 

each component included at least one contract for products and one for 

services, at least one competed and one noncompeted contract, at least 

one competed contract receiving one offer and one competed contract 

receiving multiple offers, among other factors.

To assess the reliability of the FPDS-NG data used to select the contracts 

for review, we compared key data elements from FPDS-NG to the 

contract documentation, including contract number, agency name, and 

whether or not the contract had been competed using full and open 

competition. Where we found discrepancies relevant to our methodology, 

we made adjustments to maintain the integrity of our selection criteria. 

For example, we excluded 7 contracts because the contracts were 

miscoded in FPDS-NG and therefore should have been excluded from 

our sample. Specifically, we excluded 5 contracts because they were 

small business set asides, one contract because the total dollar value fell 

below the $500,000 threshold for inclusion in the review, and one contract 

because it was a research and development contract. Because we had 

randomized lists of contracts for each of the components, we replaced the 

miscoded contracts with another contract. Once we corrected for these 

errors, we concluded the data obtained from the FPDS-NG was 

sufficiently reliable for the purposes of this review.

We excluded 2 of the 30 selected contracts from our final analysis—one 

from FHWA and one from FAA—because, as of July 31, 2014, we were 

unable to assess the market research for those contracts due to missing 

market research documentation and staff changes since the award of the 

contracts.6 As a result, our analysis in this report is based on 28 selected 

contracts (see table 2). The findings from our selected contracts are not 

generalizable to the population of all contracts within the selected 

agencies or components.

 6

At the conclusion of our review in August 2014, FHWA officials reported they had located 

the preaward documents for the contract. For the FAA contract, contracting staff were 

unable to locate the market research for the contract. In both instances the staff 

responsible for conducting, documenting, or accepting the market research were no 

longer with the organization.
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-15-8 Market Research

Table 2: Description of 28 Selected Contracts Reviewed by GAO

Contract description Agency/Component Competition

Contract dollar 

value

Higher Dollar Contracts (above $10 million)

Data communication integrated services DOT/FAA Competed, multiple offers 

received

$2,208,000,000

Tax-free fuel DOD/DLA Competed, one offer 

received

$210,384,000

Jet fuel with additives DOD/DLA Competed, multiple offers 

received

$157,272,000

Engine generator set program DOT/FAA Competed, one offer 

received

$126,587,000

Protective service officer services DHS/OPO Competed, multiple offers 

received

$86,993,000

Protective service officer services DHS/OPO Competed, multiple offers 

received

$76,975,000

Equipment maintenance program support and training 

support (bridge contract)

DHS/CBP Noncompeted $72,419,000

Coastal interceptor vessel DHS/CBP Competed, multiple offers 

received

$45,719,000

Advisory and assistance services DOD/Army Competed, multiple offers 

received

$28,500,000

Construction services DOT/FHWA Competed, multiple offers 

received

$23,360,000

Legal advisory services DOT/FHWA Competed, multiple offers 

received

$20,234,000

Construction services for foreign aid projects DOD/Army Competed, multiple offers 

received

$15,000,000

Lower Dollar Contracts (between $500,000 and $10 million)

Technical and program support DOT/FHWA Competed, multiple offers 

received

$9,642,000

Transportation standards development support DOT/FHWA Noncompeted $7,479,000

Construction of utilities infrastructure DOD/Army Noncompeted $4,047,000

Lease of copiers, multifunction devices DOD/DLA Competed, multiple offers 

received

$2,259,000

Flight simulator training DOD/Army Competed, one offer 

received

$2,067,000

Relocation of Doppler navigation system DOT/FAA Competed, multiple offers 

received

$1,631,000

Parking DHS/OPO Competed, one offer 

received

$1,585,000

Standards organization membership services DHS/OPO Noncompeted $1,500,000

Armor, transparent, vehicular window DOD/Army Noncompeted $1,132,000
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-15-8 Market Research

Contract description Agency/Component Competition

Contract dollar 

value

Recycle and store tubes of helium DHS/OPO Noncompeted $983,000

Jail space services DHS/CBP Competed, one offer 

received

$846,000

Controller monitors DOD/DLA Noncompeted $694,000

Satellite airtime DHS/CBP Noncompeted $627,000

Portable receiver systems DHS/CBP Noncompeted $609,000

Actuators DOD/DLA Noncompeted $589,000

Furniture, workstations DOT/FAA Noncompeted $538,000

Source: GAO analysis of agency documentation. | GAO-15-8.

We conducted this performance audit from August 2013 to October 2014 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Comments from the Department 

of Defense

Page 39 GAO-15-8 Market Research

Appendix II: Comments from the Department 

of Defense
Appendix II: Comments from the Department 

of Defense

Page 40 GAO-15-8 Market Research
Appendix III: Comments from the Department 

of Homeland Security

Page 41 GAO-15-8 Market Research

Appendix III: Comments from the 

Department of Homeland Security
Appendix III: Comments from the Department 

of Homeland Security

Page 42 GAO-15-8 Market Research
Appendix IV: Comments from the Department 

of Transportation

Page 43 GAO-15-8 Market Research

Appendix IV: Comments from the 

Department of Transportation
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 44 GAO-15-8 Market Research

Timothy J. DiNapoli, (202) 512-4841 or dinapolit@gao.gov

In addition to the contact named above, Penny Berrier, Assistant Director; 

Sonja Bensen, Jenny Chanley, Danielle Greene, Kristine Hassinger, Julia 

Kennon, Janet McKelvey, Guisseli Reyes-Turnell, Oziel Trevino, and 

Jocelyn Yin made key contributions to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(121159)
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