Procurement and Contract Law Exam
Prepare for your procurement and contract law exams with confidence using our Practice Exam for Procurement and Contract Law. This comprehensive study resource is designed to help students, professionals, and certification candidates master key legal principles governing procurement processes and contract agreements.
Our procurement law practice test features carefully crafted multiple-choice questions that cover essential topics, including contract formation, legal obligations, procurement policies, and dispute resolution. Each question is accompanied by a detailed explanation to reinforce learning and improve critical thinking skills.
Whether you are preparing for a contract law exam, studying for a final exam in procurement law, or seeking a procurement certification exam practice resource, this guide provides the tools you need to succeed. It also serves as a valuable procurement and contract law study guide, ensuring you gain a solid understanding of legal frameworks, risk management, and ethical considerations in procurement.
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1. Which of the following is the primary regulation governing the federal acquisition process?
A) Uniform Commercial Code (UCC)
B) Federal Acquisition Regulation (FAR)
C) Procurement Integrity Act (PIA)
D) Contract Disputes Act (CDA)
Answer: B) Federal Acquisition Regulation (FAR)
Explanation: The FAR is the primary set of rules governing the acquisition of goods and services by federal agencies. It provides guidelines on contract formation, administration, and dispute resolution.
2. A legally binding government contract must contain which of the following elements?
A) Offer, acceptance, consideration, and mutual intent
B) Offer, unilateral promise, and signed agreement
C) Government authorization and a bidder’s acceptance
D) An invitation for bid and a contractor’s response
Answer: A) Offer, acceptance, consideration, and mutual intent
Explanation: A valid contract requires these essential elements. In federal procurement, mutual intent ensures all parties agree on the terms.
3. Under the Federal Acquisition Regulation (FAR), which method is commonly used for sealed bidding?
A) Competitive negotiation
B) Two-step sealed bidding
C) Reverse auction
D) Sole-source procurement
Answer: B) Two-step sealed bidding
Explanation: This method is used when specifications are not clearly defined initially. The first step involves technical proposals, and the second step includes price bidding.
4. Which entity has the authority to resolve federal contract award protests?
A) U.S. District Court
B) Government Accountability Office (GAO)
C) The procuring agency’s legal office
D) Department of Commerce
Answer: B) Government Accountability Office (GAO)
Explanation: The GAO handles bid protests regarding alleged violations of procurement laws or regulations.
5. What is the purpose of a “debriefing” after a contract award?
A) To renegotiate contract terms
B) To provide feedback to unsuccessful offerors
C) To publicly disclose all competing bid prices
D) To allow bidders to protest the decision directly
Answer: B) To provide feedback to unsuccessful offerors
Explanation: FAR mandates debriefings to help offerors understand the basis for the contract award and improve future proposals.
6. What is the role of a Contracting Officer (CO) in federal procurement?
A) Ensure contracts comply with the FAR
B) Approve payments for contractors
C) Represent the contractor in disputes
D) Lobby for procurement reforms
Answer: A) Ensure contracts comply with the FAR
Explanation: The CO has the legal authority to bind the government to contracts and ensure compliance with FAR requirements.
7. Under the FAR, a contractor is required to disclose evidence of fraud or violations of law when the contract value exceeds:
A) $10,000
B) $150,000
C) $500,000
D) $5,000,000
Answer: D) $5,000,000
Explanation: The FAR requires contractors to disclose violations related to fraud, conflicts of interest, or bribery for contracts above this threshold.
8. Which type of contract is used when costs cannot be estimated with accuracy and includes a negotiated profit?
A) Fixed-price contract
B) Cost-reimbursement contract
C) Indefinite-delivery contract
D) Time-and-materials contract
Answer: B) Cost-reimbursement contract
Explanation: Cost-reimbursement contracts allow for payment of allowable expenses plus a negotiated fee, making them suitable when costs are uncertain.
9. What must an agency consider before awarding a sole-source contract?
A) Market research justifying lack of competition
B) The contractor’s lobbying history
C) Number of past contracts awarded to the contractor
D) Contractor’s relationship with the agency head
Answer: A) Market research justifying lack of competition
Explanation: Sole-source contracts require justification based on market research proving that only one source can fulfill the requirement.
10. What is a “cure notice” in government contracting?
A) A warning that contract performance is at risk
B) An official termination notice
C) A request for a contract extension
D) A final payment approval
Answer: A) A warning that contract performance is at risk
Explanation: A cure notice notifies a contractor of deficiencies and provides an opportunity to correct them before contract termination.
11. Under the Federal Acquisition Regulation (FAR), which contract type places the most cost risk on the contractor?
A) Time-and-materials contract
B) Cost-reimbursement contract
C) Fixed-price contract
D) Letter contract
Answer: C) Fixed-price contract
Explanation: Fixed-price contracts require the contractor to deliver at the agreed-upon price, regardless of actual costs, placing the financial risk on them.
12. What is the main purpose of the Competition in Contracting Act (CICA)?
A) To promote full and open competition in government procurement
B) To allow agencies to award contracts without competition
C) To regulate contractor salaries in government contracts
D) To provide exclusive contracting opportunities to small businesses
Answer: A) To promote full and open competition in government procurement
Explanation: CICA ensures that federal contracts are awarded through fair and open competition, reducing favoritism and waste.
13. What action can a contractor take if they disagree with a contracting officer’s decision under the Contract Disputes Act (CDA)?
A) Appeal to the Government Accountability Office (GAO)
B) File a lawsuit in federal district court immediately
C) Appeal to the appropriate Board of Contract Appeals (BCA) or U.S. Court of Federal Claims
D) Request a renegotiation of contract terms
Answer: C) Appeal to the appropriate Board of Contract Appeals (BCA) or U.S. Court of Federal Claims
Explanation: Contractors can appeal a CO’s decision to the agency’s Board of Contract Appeals or the U.S. Court of Federal Claims.
14. When must a bid protest be filed with the Government Accountability Office (GAO)?
A) Within 5 days of the contract award
B) Within 10 days after the basis of protest is known
C) Within 30 days after contract performance starts
D) At any time during contract performance
Answer: B) Within 10 days after the basis of protest is known
Explanation: The GAO requires protests to be filed within 10 days of when the protester knew (or should have known) the grounds for the protest.
15. Which of the following is NOT a valid basis for filing a bid protest?
A) The agency failed to follow the evaluation criteria in the solicitation
B) The contractor was not awarded the contract despite having the lowest price
C) The solicitation contained vague or restrictive requirements
D) The agency conducted an unfair and biased evaluation process
Answer: B) The contractor was not awarded the contract despite having the lowest price
Explanation: The lowest price alone does not guarantee a contract award; agencies must consider all evaluation factors in the solicitation.
16. What is the purpose of a “termination for convenience” clause in government contracts?
A) To allow the contractor to cancel the contract at any time
B) To allow the government to end the contract without contractor fault
C) To provide compensation to a contractor for delays
D) To resolve disputes related to contract performance
Answer: B) To allow the government to end the contract without contractor fault
Explanation: This clause permits the government to terminate a contract when it is in its best interest, even if the contractor is not at fault.
17. The Anti-Deficiency Act prohibits government officials from:
A) Making unauthorized contract modifications
B) Spending funds before they are appropriated
C) Awarding contracts based solely on political influence
D) Disclosing procurement-sensitive information
Answer: B) Spending funds before they are appropriated
Explanation: The Anti-Deficiency Act prevents government officials from obligating funds beyond what has been appropriated by Congress.
18. In federal procurement, what does “best value” mean?
A) Awarding a contract to the lowest-priced bidder
B) Selecting the proposal that provides the best balance of cost and performance
C) Awarding contracts only to large businesses
D) Choosing the contractor with the highest past performance ratings
Answer: B) Selecting the proposal that provides the best balance of cost and performance
Explanation: Best value means considering both price and other factors such as technical expertise, quality, and past performance.
19. The Procurement Integrity Act prohibits:
A) Contractors from submitting multiple bids on a single contract
B) Government officials from disclosing proprietary or source selection information before contract award
C) The use of fixed-price contracts in federal procurement
D) The evaluation of past performance in contract awards
Answer: B) Government officials from disclosing proprietary or source selection information before contract award
Explanation: The act ensures fairness by preventing the release of sensitive procurement information that could give an unfair advantage.
20. What is a Contracting Officer’s Representative (COR) responsible for?
A) Signing contracts on behalf of the government
B) Approving contract modifications
C) Monitoring contract performance and ensuring compliance
D) Making final decisions on contract disputes
Answer: C) Monitoring contract performance and ensuring compliance
Explanation: A COR oversees contractor performance and compliance but does not have authority to bind the government.
21. What is a “change order” in government contracting?
A) A request for a new procurement
B) A directive modifying contract terms
C) A termination notice
D) A protest resolution process
Answer: B) A directive modifying contract terms
Explanation: Change orders alter contract scope, cost, or schedule and must be properly documented.
22. Under the FAR, which contract type provides the government with maximum pricing control?
A) Cost-plus-fixed-fee contract
B) Fixed-price contract
C) Indefinite-delivery contract
D) Time-and-materials contract
Answer: B) Fixed-price contract
Explanation: Fixed-price contracts limit the government’s cost risk, as the contractor bears the financial responsibility for overruns.
23. A “constructive change” occurs when:
A) The contractor performs work beyond the contract scope due to government direction
B) The government modifies a contract formally in writing
C) A contract is terminated for default
D) The contractor requests additional payment for materials
Answer: A) The contractor performs work beyond the contract scope due to government direction
Explanation: Constructive changes happen when government actions (even unintended ones) cause additional contractor work without a formal contract modification.
24. What does a “default termination” mean for a government contractor?
A) The contractor failed to meet contractual obligations
B) The contract was completed ahead of schedule
C) The contractor successfully appealed a dispute
D) The government voluntarily terminated the contract
Answer: A) The contractor failed to meet contractual obligations
Explanation: Default termination occurs when a contractor does not meet contract requirements, possibly leading to financial penalties.
25. The Davis-Bacon Act requires:
A) Federal contractors to pay prevailing wages to laborers on public works projects
B) Agencies to follow a sealed bidding process
C) Contractors to report fraud within 60 days
D) Small business set-asides for federal contracts
Answer: A) Federal contractors to pay prevailing wages to laborers on public works projects
Explanation: The act ensures fair wages on federally funded construction projects.
26. Under the Small Business Act, what is the purpose of small business set-asides in federal procurement?
A) To ensure all contracts are awarded to large firms
B) To increase competition among major government contractors
C) To promote small business participation in federal contracting
D) To allow small businesses to subcontract their work to larger firms
Answer: C) To promote small business participation in federal contracting
Explanation: The Small Business Act mandates set-asides to encourage small businesses to compete for and receive federal contracts.
27. Which of the following is TRUE regarding the False Claims Act (FCA) in government contracting?
A) It applies only to state and local contracts
B) It prohibits contractors from making fraudulent claims for payment
C) It allows contractors to submit false invoices as long as they correct them later
D) It exempts federal contractors from liability for billing errors
Answer: B) It prohibits contractors from making fraudulent claims for payment
Explanation: The FCA holds contractors liable for knowingly submitting false claims or invoices to the government, with potential penalties.
28. The Prompt Payment Act requires federal agencies to pay contractors within how many days of receiving a proper invoice?
A) 7 days
B) 15 days
C) 30 days
D) 60 days
Answer: C) 30 days
Explanation: The Prompt Payment Act ensures that federal agencies pay contractors within 30 days unless otherwise specified in the contract.
29. What is the primary purpose of the Suspension and Debarment process in federal procurement?
A) To allow agencies to renegotiate contracts
B) To exclude unethical or non-compliant contractors from receiving government contracts
C) To ensure only the lowest bidder is awarded contracts
D) To punish contractors for minor administrative errors
Answer: B) To exclude unethical or non-compliant contractors from receiving government contracts
Explanation: Suspension and debarment prevent fraudulent or irresponsible contractors from bidding on future federal contracts.
30. What is a “claim” under the Contract Disputes Act (CDA)?
A) A formal request by a contractor or government agency for contract adjustments
B) A legal case filed in federal court against the contracting officer
C) A government request for additional work without payment
D) A bid protest regarding an unfair contract award
Answer: A) A formal request by a contractor or government agency for contract adjustments
Explanation: Under the CDA, a claim is a formal request seeking payment, time extensions, or other contract adjustments.
31. Which of the following is NOT a valid reason for the government to issue a termination for default?
A) The contractor failed to deliver within the specified time
B) The contractor’s price was higher than a competitor’s bid
C) The contractor failed to meet performance standards
D) The contractor abandoned the project without cause
Answer: B) The contractor’s price was higher than a competitor’s bid
Explanation: Termination for default is based on contractor non-performance, not price comparisons after the contract is awarded.
32. What is the primary purpose of a “liquidated damages” clause in a government contract?
A) To compensate the government for contractor performance exceeding expectations
B) To penalize contractors for not hiring enough employees
C) To establish predetermined damages for late or deficient performance
D) To reduce the contract value in case of disputes
Answer: C) To establish predetermined damages for late or deficient performance
Explanation: Liquidated damages clauses define compensation amounts if a contractor fails to meet deadlines or performance requirements.
33. The Federal Acquisition Regulation (FAR) requires government agencies to evaluate contractors based on which key factors?
A) Cost, technical capability, and past performance
B) Cost only
C) Political affiliations of the contractor
D) Length of time the contractor has been in business
Answer: A) Cost, technical capability, and past performance
Explanation: FAR mandates these three factors for contract awards to ensure best value for the government.
34. Under the Contract Disputes Act (CDA), a contractor must submit a written claim to the contracting officer for disputes involving amounts exceeding:
A) $10,000
B) $50,000
C) $100,000
D) $500,000
Answer: C) $100,000
Explanation: Claims exceeding $100,000 must be certified and submitted to the contracting officer under the CDA.
35. What is the purpose of an “indefinite-delivery, indefinite-quantity” (IDIQ) contract?
A) To allow contractors to submit unlimited bids
B) To provide flexibility in purchasing recurring goods and services
C) To guarantee a fixed quantity of goods
D) To eliminate competition in government contracts
Answer: B) To provide flexibility in purchasing recurring goods and services
Explanation: IDIQ contracts allow agencies to order varying quantities of supplies or services as needed.
36. What is a “request for equitable adjustment” (REA) in government contracting?
A) A request by a contractor for additional compensation due to changes in contract scope
B) A request to modify payment terms
C) A protest against an awarded contract
D) A request to terminate a contract
Answer: A) A request by a contractor for additional compensation due to changes in contract scope
Explanation: An REA allows contractors to seek compensation or schedule adjustments when the government changes contract terms.
37. The Buy American Act requires federal agencies to prioritize:
A) The lowest-priced foreign products
B) Domestic products and materials in government purchases
C) Exclusive contracts with non-U.S. suppliers
D) Only small businesses in contract awards
Answer: B) Domestic products and materials in government purchases
Explanation: The Buy American Act encourages federal agencies to purchase U.S.-made products to support domestic industries.
38. Under the FAR, which of the following is considered a “prohibited practice” in government contracting?
A) Offering gifts or kickbacks to government officials
B) Subcontracting work to small businesses
C) Using price as an evaluation factor
D) Conducting market research before awarding a contract
Answer: A) Offering gifts or kickbacks to government officials
Explanation: The FAR prohibits bribery, kickbacks, and other unethical practices to maintain fair and transparent procurement.
39. What is the purpose of a “past performance evaluation” in federal procurement?
A) To determine a contractor’s likelihood of success on future contracts
B) To compare the prices of different contractors
C) To ensure that only new contractors receive awards
D) To evaluate a contractor’s financial health
Answer: A) To determine a contractor’s likelihood of success on future contracts
Explanation: Past performance is a key evaluation factor, helping agencies assess a contractor’s reliability and quality of work.
40. Which act requires government contractors to provide equal employment opportunities?
A) Davis-Bacon Act
B) Equal Employment Opportunity (EEO) Act
C) Buy American Act
D) Procurement Integrity Act
Answer: B) Equal Employment Opportunity (EEO) Act
Explanation: The EEO Act prohibits discrimination and ensures equal hiring practices in government contracts.
41. What is “bid rigging” in federal procurement?
A) The legal practice of submitting a joint bid
B) A fraudulent agreement among bidders to manipulate contract awards
C) A strategy to offer the lowest possible price
D) A method of protesting contract awards
Answer: B) A fraudulent agreement among bidders to manipulate contract awards
Explanation: Bid rigging is an illegal practice where bidders collude to fix prices or predetermine the contract award.
42. What is the primary function of the Office of Federal Procurement Policy (OFPP)?
A) To regulate private-sector procurement
B) To oversee and improve federal procurement policies
C) To conduct audits of all government contractors
D) To terminate non-performing contracts
Answer: B) To oversee and improve federal procurement policies
Explanation: The OFPP establishes policies to enhance efficiency and fairness in federal acquisitions.
43. A “sole-source contract” is awarded when:
A) Only one supplier can fulfill the contract requirements
B) The contractor has the lowest price
C) There are multiple vendors competing
D) The government is conducting a reverse auction
Answer: A) Only one supplier can fulfill the contract requirements
Explanation: Sole-source contracts require justification that only one provider can meet the agency’s needs.
44. The Federal Claims Court primarily handles:
A) Protests of small business contracts
B) Disputes over federal government contracts
C) Private-sector procurement lawsuits
D) Criminal cases related to procurement fraud
Answer: B) Disputes over federal government contracts
Explanation: The U.S. Court of Federal Claims resolves contract disputes between contractors and federal agencies.
45. Under the FAR, a “reasonable price” is determined by:
A) Comparing prices from similar contracts
B) Contractor preferences
C) Historical performance of the contractor
D) The highest bid submitted
Answer: A) Comparing prices from similar contracts
Explanation: The FAR requires agencies to assess prices based on market data, prior contracts, and competition.
46. What is the purpose of a “defective pricing” clause?
A) To prevent overpricing due to inaccurate cost estimates
B) To allow price renegotiation at any time
C) To reduce the contract’s performance period
D) To give contractors flexibility in setting prices
Answer: A) To prevent overpricing due to inaccurate cost estimates
Explanation: Defective pricing clauses protect the government from inflated contract costs based on misleading or incorrect cost data.
47. What is the primary role of a Contracting Officer’s Technical Representative (COTR)?
A) To oversee technical aspects of contract performance
B) To approve contract terminations
C) To make final payment decisions
D) To award contracts
Answer: A) To oversee technical aspects of contract performance
Explanation: A COTR provides technical oversight and ensures contract compliance.
48. Under the FAR, which type of contract provides a fixed price with possible additional payments for superior performance?
A) Cost-plus-fixed-fee contract
B) Fixed-price-incentive contract
C) Time-and-materials contract
D) Cost-reimbursement contract
Answer: B) Fixed-price-incentive contract
Explanation: These contracts offer financial incentives for exceeding performance standards.
49. The Miller Act requires:
A) Performance and payment bonds for federal construction contracts
B) Federal agencies to buy only U.S.-made products
C) Small business set-asides for all contracts
D) Price negotiations before contract awards
Answer: A) Performance and payment bonds for federal construction contracts
Explanation: The Miller Act ensures contractors provide security for project completion and subcontractor payment.
50. What is the primary purpose of “commercial item acquisitions” under the FAR?
A) To streamline procurement of widely available products
B) To ensure all purchases are made through large contractors
C) To eliminate competition in federal acquisitions
D) To increase government spending
Answer: A) To streamline procurement of widely available products
Explanation: Commercial item acquisitions simplify purchasing processes for products commonly sold to the public.
51. What is the primary objective of the Federal Acquisition Regulation (FAR)?
A) To eliminate competition in government procurement
B) To ensure efficiency, fairness, and transparency in federal contracting
C) To require contracts be awarded to the lowest bidder only
D) To reduce the number of government contracts issued
Answer: B) To ensure efficiency, fairness, and transparency in federal contracting
Explanation: The FAR sets uniform policies and procedures to regulate federal acquisition processes.
52. Under the Competition in Contracting Act (CICA), full and open competition is required unless:
A) A contracting officer prefers a specific vendor
B) A sole-source award is justified
C) The contract is valued at less than $10,000
D) A foreign supplier offers lower prices
Answer: B) A sole-source award is justified
Explanation: CICA mandates full and open competition unless a legally valid exception applies, such as urgent need or only one responsible source.
53. What is the primary role of the Government Accountability Office (GAO) in contract disputes?
A) To oversee government budget spending
B) To review and resolve bid protests
C) To negotiate contracts for federal agencies
D) To terminate government contracts
Answer: B) To review and resolve bid protests
Explanation: The GAO handles bid protests and ensures agencies comply with procurement regulations.
54. Which type of government contract places the most financial risk on the contractor?
A) Cost-plus-fixed-fee contract
B) Firm-fixed-price contract
C) Time-and-materials contract
D) Cost-reimbursement contract
Answer: B) Firm-fixed-price contract
Explanation: A firm-fixed-price contract requires the contractor to complete work for a set price, regardless of actual costs.
55. What does “scope of work” define in a government contract?
A) The contractor’s financial obligations
B) The work to be performed and deliverables required
C) The legal penalties for contract non-compliance
D) The government’s payment terms
Answer: B) The work to be performed and deliverables required
Explanation: The scope of work details the specific tasks, performance expectations, and deliverables.
56. A contractor can challenge an unfair contract award by filing a:
A) Performance bond
B) Bid protest
C) Subcontracting plan
D) Termination request
Answer: B) Bid protest
Explanation: A bid protest allows contractors to challenge contract awards that violate procurement rules.
57. Under the Contract Disputes Act (CDA), which entity resolves contract disputes if the contracting officer’s decision is contested?
A) U.S. Court of Federal Claims or Board of Contract Appeals
B) Government Accountability Office (GAO)
C) Department of Justice
D) The awarding agency
Answer: A) U.S. Court of Federal Claims or Board of Contract Appeals
Explanation: Contractors may appeal a contracting officer’s decision to these entities under the CDA.
58. What does the “Christian Doctrine” state in government contracting?
A) Mandatory FAR clauses are included in contracts by law, even if omitted
B) Contractors can modify federal contracts at their discretion
C) Subcontractors are immune from government liability
D) All contracts must be awarded based on the lowest price
Answer: A) Mandatory FAR clauses are included in contracts by law, even if omitted
Explanation: The Christian Doctrine holds that essential FAR clauses apply even if not explicitly written in the contract.
59. Which of the following is a key requirement for government contractors under the Truthful Cost or Pricing Data Act (formerly TINA)?
A) To provide certified cost and pricing data for contracts above the threshold
B) To guarantee the lowest price in all bids
C) To accept all government contract modifications
D) To submit only performance-related data
Answer: A) To provide certified cost and pricing data for contracts above the threshold
Explanation: This act requires contractors to disclose accurate cost data for non-competitive contracts exceeding a set threshold.
60. What is a “letter contract” in government procurement?
A) A contract awarded without formal competition
B) A preliminary agreement authorizing work before final contract terms are settled
C) A contract amendment modifying the original terms
D) A contract requiring only verbal approval
Answer: B) A preliminary agreement authorizing work before final contract terms are settled
Explanation: Letter contracts allow work to begin while final terms are negotiated.
61. What does the Procurement Integrity Act prohibit?
A) Unfair competition among commercial businesses
B) Disclosure of contractor bid or proposal information before award
C) The use of performance-based contracting
D) Contracts with small businesses
Answer: B) Disclosure of contractor bid or proposal information before award
Explanation: The Procurement Integrity Act prevents improper influence and protects confidential procurement information.
62. What is the primary purpose of a “stop-work order” in government contracting?
A) To immediately halt contract performance due to issues such as funding or scope changes
B) To terminate a contract permanently
C) To penalize a contractor for minor infractions
D) To delay contract payments
Answer: A) To immediately halt contract performance due to issues such as funding or scope changes
Explanation: Stop-work orders temporarily suspend performance to address significant contract issues.
63. What is “novation” in government contracting?
A) The substitution of a new contractor in place of the original one
B) The termination of a government contract
C) A process of contract renewal
D) A penalty for contract non-performance
Answer: A) The substitution of a new contractor in place of the original one
Explanation: Novation agreements transfer contract obligations to a new party with government approval.
64. Which federal agency is primarily responsible for investigating procurement fraud?
A) Federal Bureau of Investigation (FBI)
B) Small Business Administration (SBA)
C) Department of Agriculture
D) Office of Personnel Management (OPM)
Answer: A) Federal Bureau of Investigation (FBI)
Explanation: The FBI investigates procurement fraud and contract-related crimes.
65. The Davis-Bacon Act requires federal contractors to:
A) Pay prevailing wages to construction workers on public projects
B) Purchase only American-made goods
C) Provide benefits to subcontractors
D) Use only fixed-price contracts
Answer: A) Pay prevailing wages to construction workers on public projects
Explanation: The Davis-Bacon Act ensures fair wages for laborers working on federally funded construction projects.
66. Which of the following is NOT considered an allowable cost under a cost-reimbursement contract?
A) Direct labor costs
B) Travel expenses related to contract performance
C) Lobbying expenses
D) Equipment required to perform the contract
Answer: C) Lobbying expenses
Explanation: FAR prohibits lobbying costs from being charged to government contracts.
67. What is the purpose of a Performance Work Statement (PWS)?
A) To define contract performance expectations in terms of outcomes
B) To establish penalties for contract non-performance
C) To limit the contractor’s ability to adjust pricing
D) To set fixed deadlines for all government contracts
Answer: A) To define contract performance expectations in terms of outcomes
Explanation: A PWS describes the required performance results rather than detailed work processes.
68. A Time-and-Materials (T&M) contract is appropriate when:
A) The extent of work is uncertain and cannot be defined in advance
B) A firm-fixed-price contract is not available
C) The contract is for commercial off-the-shelf items
D) The contractor prefers more flexibility
Answer: A) The extent of work is uncertain and cannot be defined in advance
Explanation: T&M contracts allow for flexibility in pricing based on labor hours and materials used.
69. What is the primary function of a “payment bond” in federal contracts?
A) To guarantee payment to subcontractors and suppliers
B) To secure contractor financing
C) To ensure contract price stability
D) To allow payment delays
Answer: A) To guarantee payment to subcontractors and suppliers
Explanation: Payment bonds protect subcontractors and suppliers by ensuring they receive payment for work performed.
70. The Anti-Kickback Act prohibits:
A) Contractors from offering payments to gain favorable treatment in federal contracts
B) Contractors from increasing contract prices
C) Agencies from terminating contracts
D) Government employees from negotiating with contractors
Answer: A) Contractors from offering payments to gain favorable treatment in federal contracts
Explanation: The Anti-Kickback Act prevents bribery and unethical payments in government contracting.
71. Which of the following is NOT a legitimate basis for a bid protest?
A) The agency failed to follow the solicitation criteria
B) The protester disagrees with the agency’s decision
C) A conflict of interest existed during the evaluation process
D) The agency improperly restricted competition
Answer: B) The protester disagrees with the agency’s decision
Explanation: A protest must be based on a violation of procurement law or regulations, not just disagreement with the decision.
72. What is a “debriefing” in federal procurement?
A) A meeting where the contractor provides updates on project performance
B) A process where the government explains why a proposal was accepted or rejected
C) A discussion to renegotiate contract terms
D) A mandatory training session for all bidders
Answer: B) A process where the government explains why a proposal was accepted or rejected
Explanation: Debriefings provide transparency in the selection process and help bidders improve future proposals.
73. Under FAR, which contract type provides the least risk to the government?
A) Cost-plus-incentive-fee
B) Firm-fixed-price
C) Time-and-materials
D) Cost-reimbursement
Answer: B) Firm-fixed-price
Explanation: Firm-fixed-price contracts place the cost risk on the contractor, making it less risky for the government.
74. What is the purpose of a “liquidated damages” clause in a contract?
A) To penalize the contractor for submitting a late proposal
B) To compensate the government for anticipated losses due to delays
C) To encourage competition among bidders
D) To allow the contractor to terminate the agreement at will
Answer: B) To compensate the government for anticipated losses due to delays
Explanation: Liquidated damages clauses provide a predetermined amount for damages caused by contract delays.
75. The Buy American Act requires federal agencies to:
A) Procure only from U.S. companies, with limited exceptions
B) Buy goods based on the lowest price regardless of origin
C) Prohibit contracts with foreign vendors
D) Exclude all foreign suppliers from government contracts
Answer: A) Procure only from U.S. companies, with limited exceptions
Explanation: The Buy American Act mandates preference for domestic goods, with some exceptions for cost or trade agreements.
76. What is an “equitable adjustment” in a government contract?
A) A change to the contract price or schedule due to a modification
B) A bonus payment for early project completion
C) A penalty for nonperformance
D) A mandatory price reduction for government contracts
Answer: A) A change to the contract price or schedule due to a modification
Explanation: An equitable adjustment compensates contractors for cost increases due to changes ordered by the government.
77. A “termination for convenience” allows the government to:
A) Terminate a contract without contractor fault
B) Cancel a contract only for nonperformance
C) Require the contractor to pay a penalty
D) Stop work indefinitely without compensation
Answer: A) Terminate a contract without contractor fault
Explanation: The government can terminate contracts for convenience when in its best interest, even if the contractor is performing well.
78. What is a “definitive responsibility criterion” in government procurement?
A) A specific standard a contractor must meet to be eligible for award
B) A requirement that all government contracts be cost-plus contracts
C) A rule that bid protests must be resolved within 30 days
D) A provision that limits contractor liability
Answer: A) A specific standard a contractor must meet to be eligible for award
Explanation: These are objective criteria that contractors must satisfy to be deemed responsible bidders.
79. What does “de facto debarment” refer to?
A) A contractor being effectively excluded from competition without formal debarment
B) A legal requirement to terminate a contract
C) A government mandate to award contracts to only U.S. vendors
D) A clause allowing automatic contract extensions
Answer: A) A contractor being effectively excluded from competition without formal debarment
Explanation: De facto debarment occurs when a contractor is repeatedly denied contract awards without official suspension or debarment.
80. Which entity is responsible for issuing federal procurement regulations?
A) Federal Acquisition Regulatory Council
B) General Services Administration (GSA)
C) Office of Personnel Management (OPM)
D) Department of Commerce
Answer: A) Federal Acquisition Regulatory Council
Explanation: The FAR Council oversees procurement regulations and updates the FAR.
81. What is the purpose of an “organizational conflict of interest” (OCI) clause in a contract?
A) To prevent unfair competitive advantages in government contracts
B) To ensure the lowest-cost bidder wins
C) To require agencies to justify contract decisions
D) To allow subcontracting with any company
Answer: A) To prevent unfair competitive advantages in government contracts
Explanation: OCI clauses ensure that contractors do not have conflicting roles that could bias procurement decisions.
82. Which of the following is NOT a valid reason for a contracting officer to reject a bid?
A) The bid was submitted after the deadline
B) The contractor has no prior government contracting experience
C) The bid failed to meet the solicitation requirements
D) The contractor has been suspended or debarred
Answer: B) The contractor has no prior government contracting experience
Explanation: Government contracts can be awarded to new contractors if they meet all other requirements.
83. What is “past performance” in the context of federal procurement?
A) A record of a contractor’s previous work quality and reliability
B) A government certification requirement
C) A financial assessment of a contractor’s assets
D) A bidding requirement for all contracts
Answer: A) A record of a contractor’s previous work quality and reliability
Explanation: Agencies evaluate past performance to determine a contractor’s ability to fulfill contract obligations.
84. The Prompt Payment Act requires the federal government to:
A) Pay contractors in a timely manner
B) Award contracts within 30 days
C) Allow only electronic payment methods
D) Reimburse contractors for bid preparation costs
Answer: A) Pay contractors in a timely manner
Explanation: The Act sets deadlines for government payments to contractors to prevent financial strain.
85. What is a “performance bond” in government contracting?
A) A guarantee that a contractor will complete the contract as required
B) A financial penalty for late project completion
C) A tax imposed on government contractors
D) A requirement for cost-plus contracts only
Answer: A) A guarantee that a contractor will complete the contract as required
Explanation: Performance bonds ensure the contractor completes the project according to contract terms.
86. The Small Business Administration (SBA) assists federal contractors by:
A) Helping small businesses secure government contracts
B) Enforcing the FAR
C) Selecting winning bids for government contracts
D) Conducting audits on large contractors
Answer: A) Helping small businesses secure government contracts
Explanation: The SBA supports small businesses by providing resources and access to government contracts.
87. Which of the following contracts is most appropriate when it is difficult to estimate costs in advance?
A) Firm-fixed-price contract
B) Cost-plus-incentive-fee contract
C) Sealed-bid contract
D) Requirements contract
Answer: B) Cost-plus-incentive-fee contract
Explanation: Cost-plus-incentive-fee contracts allow the government to reimburse allowable costs while providing incentives for cost control.
88. What is the primary purpose of the Contract Work Hours and Safety Standards Act (CWHSSA)?
A) To ensure fair labor wages in government contracts
B) To limit the number of government contracts issued per year
C) To require cost-plus contracts for public projects
D) To regulate contract disputes between the government and vendors
Answer: A) To ensure fair labor wages in government contracts
Explanation: CWHSSA sets overtime pay standards for federal contract workers.
89. Which government office enforces suspension and debarment actions against contractors?
A) The contracting agency’s Suspension and Debarment Official (SDO)
B) The U.S. Supreme Court
C) The Department of Commerce
D) The Federal Labor Relations Authority
Answer: A) The contracting agency’s Suspension and Debarment Official (SDO)
Explanation: The SDO evaluates contractor responsibility and can suspend or debar firms that violate procurement laws.
90. Under FAR Part 15, discussions during a negotiated procurement are intended to:
A) Provide offerors an opportunity to revise their proposals
B) Reject all proposals that exceed budget limits
C) Automatically award contracts to the lowest bidder
D) Allow agencies to select vendors without competition
Answer: A) Provide offerors an opportunity to revise their proposals
Explanation: Negotiated procurements allow discussions for clarification and proposal revision before awarding a contract.
91. Which law requires full and open competition in federal contracting?
A) Competition in Contracting Act (CICA)
B) Buy American Act
C) Truth in Negotiations Act
D) Prompt Payment Act
Answer: A) Competition in Contracting Act (CICA)
Explanation: CICA promotes fair competition to ensure government contracts are awarded based on merit.
92. What is a “task order” in a government contract?
A) An order for specific work under an indefinite-delivery/indefinite-quantity (IDIQ) contract
B) A modification that cancels a government contract
C) A penalty for nonperformance
D) A type of contract that only applies to small businesses
Answer: A) An order for specific work under an indefinite-delivery/indefinite-quantity (IDIQ) contract
Explanation: Task orders authorize specific work under an IDIQ contract.
93. Which of the following is NOT an exception to full and open competition under FAR?
A) Urgent and compelling need
B) Sole-source justification
C) Agency preference for a contractor
D) National security concerns
Answer: C) Agency preference for a contractor
Explanation: Agency preference alone is not a valid justification for avoiding competition.
94. The Federal Tort Claims Act (FTCA) allows:
A) Private citizens to sue the federal government for certain wrongful acts
B) Contractors to charge the government for all indirect costs
C) The government to terminate contracts for default
D) Government employees to ignore contract disputes
Answer: A) Private citizens to sue the federal government for certain wrongful acts
Explanation: The FTCA provides limited waivers of sovereign immunity, allowing lawsuits against the U.S. government for torts committed by its employees.
95. Which procurement method is most appropriate for complex contracts requiring evaluation beyond price alone?
A) Sealed bidding
B) Request for proposals (RFP)
C) Micro-purchase
D) Reverse auction
Answer: B) Request for proposals (RFP)
Explanation: RFPs allow agencies to evaluate multiple factors, including technical expertise and past performance.
96. When can a contractor submit a claim under the Contract Disputes Act (CDA)?
A) Only after contract completion
B) Any time during contract performance or within six years of claim accrual
C) Only after an award protest is resolved
D) Only if the contract was terminated
Answer: B) Any time during contract performance or within six years of claim accrual
Explanation: The CDA allows contractors to file claims within six years of when the claim accrues.
97. What is the primary function of the Defense Contract Audit Agency (DCAA)?
A) To audit contractor costs and financial practices
B) To resolve contract disputes
C) To approve all federal contracts
D) To oversee state procurement policies
Answer: A) To audit contractor costs and financial practices
Explanation: The DCAA ensures financial compliance in defense contracts.
98. What is “flow-down” in government contracting?
A) The requirement for prime contractors to pass certain contract clauses to subcontractors
B) A method of dispute resolution
C) A penalty for nonperformance
D) A strategy to increase government contract funding
Answer: A) The requirement for prime contractors to pass certain contract clauses to subcontractors
Explanation: FAR clauses often require prime contractors to impose similar terms on their subcontractors.
99. What is the “fair opportunity” rule under FAR Part 16?
A) It requires agencies to provide all multiple-award IDIQ holders a chance to compete for task orders
B) It guarantees contracts for small businesses
C) It limits competition to pre-approved vendors
D) It applies only to firm-fixed-price contracts
Answer: A) It requires agencies to provide all multiple-award IDIQ holders a chance to compete for task orders
Explanation: The fair opportunity rule ensures equal competition among multiple-award contract holders.
100. What is the purpose of the False Claims Act in federal contracting?
A) To penalize contractors who submit fraudulent claims to the government
B) To protect whistleblowers in private-sector contracts
C) To provide tax incentives for government contractors
D) To encourage small businesses to compete for contracts
Answer: A) To penalize contractors who submit fraudulent claims to the government
Explanation: The False Claims Act imposes heavy penalties on those who knowingly submit false claims to the government.
101. Which of the following is NOT a key principle of federal procurement under the FAR?
A) Full and open competition
B) Best value procurement
C) Contractor selection based solely on past performance
D) Transparency in the procurement process
Answer: C) Contractor selection based solely on past performance
Explanation: Past performance is one factor in contract awards, but selection must consider multiple evaluation criteria.
102. What is the primary purpose of the Procurement Integrity Act?
A) To prevent unfair advantages and conflicts of interest in government contracting
B) To regulate contract pricing for small businesses
C) To allow sole-source awards for federal contractors
D) To provide agencies unlimited flexibility in contractor selection
Answer: A) To prevent unfair advantages and conflicts of interest in government contracting
Explanation: The Procurement Integrity Act prohibits improper disclosures and conflicts of interest in federal procurement.
103. Under the FAR, what is the purpose of a Contracting Officer’s (CO) warrant?
A) To authorize a CO to enter into, administer, or terminate contracts
B) To allow agencies to override procurement regulations
C) To guarantee that a contract will be awarded to the lowest bidder
D) To approve payments without verification
Answer: A) To authorize a CO to enter into, administer, or terminate contracts
Explanation: A CO must have a warrant that grants the authority to obligate government funds.
104. What does the Brooks Act require for federal procurement of architectural and engineering services?
A) Selection based on qualifications rather than price
B) Awarding contracts to the lowest-priced offeror
C) Requiring all A&E contracts to be firm-fixed-price
D) Prohibiting government contracts for private engineering firms
Answer: A) Selection based on qualifications rather than price
Explanation: The Brooks Act mandates qualifications-based selection (QBS) for A&E services.
105. What is the primary function of the Government Accountability Office (GAO) in federal contracting?
A) Reviewing and deciding bid protests
B) Issuing debarment orders
C) Conducting contract performance audits
D) Negotiating contract terms on behalf of agencies
Answer: A) Reviewing and deciding bid protests
Explanation: The GAO adjudicates bid protests and ensures compliance with procurement laws.
106. What is the purpose of the Truthful Cost or Pricing Data Act (formerly the Truth in Negotiations Act, or TINA)?
A) To require contractors to submit accurate cost and pricing data for certain contracts
B) To limit contract awards to large businesses
C) To allow automatic price escalations in long-term contracts
D) To prohibit price negotiations in federal contracting
Answer: A) To require contractors to submit accurate cost and pricing data for certain contracts
Explanation: TINA ensures that cost and pricing data submitted for certain government contracts are truthful and complete.
107. When is a Contracting Officer (CO) allowed to terminate a contract for default?
A) When the contractor fails to perform or meet contract requirements
B) If a contractor requests contract termination
C) When the government no longer requires the goods or services
D) If a protest is filed against the awarded contract
Answer: A) When the contractor fails to perform or meet contract requirements
Explanation: Termination for default occurs when a contractor does not fulfill contract obligations.
108. What is the purpose of an “indefinite-delivery, indefinite-quantity” (IDIQ) contract?
A) To provide flexibility in ordering supplies and services over time
B) To eliminate competition in federal procurement
C) To restrict contract modifications
D) To ensure fixed prices on all government contracts
Answer: A) To provide flexibility in ordering supplies and services over time
Explanation: IDIQ contracts allow agencies to place orders for goods and services as needed within a contract period.
109. What is a “cure notice” in government contracting?
A) A written notice given to a contractor to correct deficiencies before termination for default
B) A government notice of contract completion
C) A contractor’s request for payment adjustment
D) A notification that a protest has been dismissed
Answer: A) A written notice given to a contractor to correct deficiencies before termination for default
Explanation: A cure notice gives a contractor a chance to fix performance issues before the government terminates the contract.
110. The primary purpose of a “Justification and Approval” (J&A) document is to:
A) Justify the use of sole-source contracts
B) Approve cost-plus contracts for all federal purchases
C) Eliminate the need for contractor competition
D) Ensure only small businesses receive government contracts
Answer: A) Justify the use of sole-source contracts
Explanation: A J&A document explains why a contract should be awarded without full and open competition.
111. What is the role of the Office of Federal Procurement Policy (OFPP)?
A) To oversee government-wide procurement policies and practices
B) To approve all federal contracts over $10 million
C) To award federal contracts to the lowest bidder
D) To provide tax benefits to government contractors
Answer: A) To oversee government-wide procurement policies and practices
Explanation: The OFPP sets procurement policies to promote efficiency and integrity in government contracting.
112. Which procurement method is most appropriate for commercial items?
A) Simplified Acquisition Procedures (SAP)
B) Cost-reimbursement contracting
C) Cost-plus-fixed-fee contracting
D) Sealed bidding
Answer: A) Simplified Acquisition Procedures (SAP)
Explanation: SAP streamlines the process for acquiring commercial goods and services.
113. Which of the following best defines a “Performance-Based Acquisition” (PBA)?
A) A contract focusing on results rather than detailed processes
B) A contract where the lowest price determines the award
C) A fixed-price contract with no flexibility
D) A requirement that all contracts be time-and-materials contracts
Answer: A) A contract focusing on results rather than detailed processes
Explanation: PBAs emphasize measurable outcomes rather than specific methods of performance.
114. What is the primary role of a Contracting Officer’s Representative (COR)?
A) To monitor contract performance and ensure compliance
B) To approve final contract payments
C) To negotiate contract pricing
D) To issue contract awards
Answer: A) To monitor contract performance and ensure compliance
Explanation: CORs oversee contract execution but do not have authority to modify contracts.
115. What does the Davis-Bacon Act require for federally funded construction contracts?
A) Contractors must pay prevailing local wages to workers
B) All contracts must be awarded through sealed bidding
C) Only small businesses can bid on construction projects
D) Fixed-price contracts must be used for construction
Answer: A) Contractors must pay prevailing local wages to workers
Explanation: The Davis-Bacon Act ensures fair wages on federal construction projects.
116. Which of the following is a key requirement for a “small business set-aside” contract?
A) The contract must be reserved for small businesses meeting size standards
B) The contract must be awarded through full and open competition
C) The contractor must have at least 500 employees
D) The contract must be a cost-plus contract
Answer: A) The contract must be reserved for small businesses meeting size standards
Explanation: Small business set-asides promote opportunities for small firms in government contracting.
117. What is the primary function of the Defense Federal Acquisition Regulation Supplement (DFARS)?
A) To provide specific acquisition regulations for the Department of Defense (DoD)
B) To replace the Federal Acquisition Regulation (FAR) for all federal agencies
C) To regulate civilian agency contracts
D) To eliminate the requirement for competitive bidding
Answer: A) To provide specific acquisition regulations for the Department of Defense (DoD)
Explanation: DFARS supplements the FAR by providing additional rules for DoD procurements.
118. When can an agency use “Other Transaction Authority” (OTA)?
A) When procuring research and development projects outside traditional FAR-based contracts
B) When awarding all federal contracts
C) When purchasing office supplies under a simplified acquisition threshold
D) When modifying existing contracts for construction
Answer: A) When procuring research and development projects outside traditional FAR-based contracts
Explanation: OTAs allow flexibility in awarding contracts for innovative projects.
119. What does the Buy American Act require for federal contracts?
A) The government must give preference to American-made products
B) All federal contracts must be awarded to U.S.-based companies
C) Foreign suppliers are prohibited from bidding on federal contracts
D) The government must purchase goods at the lowest price regardless of origin
Answer: A) The government must give preference to American-made products
Explanation: The Buy American Act promotes domestic sourcing for government procurements.
120. What is the purpose of a “bid protest”?
A) To challenge the legality or fairness of a contract award decision
B) To request a contract modification
C) To terminate a contract early
D) To negotiate lower pricing on a contract
Answer: A) To challenge the legality or fairness of a contract award decision
Explanation: Bid protests allow vendors to dispute procurement decisions through GAO, the Court of Federal Claims, or the agency.
121. What is the primary function of the Small Business Administration (SBA) in federal contracting?
A) To support small businesses in obtaining federal contracts
B) To award all government contracts
C) To approve all sole-source contracts
D) To oversee contract performance for large corporations
Answer: A) To support small businesses in obtaining federal contracts
Explanation: The SBA administers small business set-asides and contracting assistance programs.
122. Which contracting method is used when the government requires a solution but does not specify how to achieve it?
A) Performance-Based Acquisition (PBA)
B) Sealed bidding
C) Sole-source contracting
D) Micro-purchasing
Answer: A) Performance-Based Acquisition (PBA)
Explanation: PBAs focus on achieving results rather than specifying how work must be performed.
123. What is the primary benefit of using a General Services Administration (GSA) Schedule contract?
A) It streamlines the procurement process for commonly used goods and services
B) It eliminates the need for government agencies to follow the FAR
C) It restricts contract awards to small businesses
D) It allows agencies to award contracts without competition
Answer: A) It streamlines the procurement process for commonly used goods and services
Explanation: GSA Schedule contracts offer pre-negotiated pricing for frequently purchased goods and services.
124. Under the FAR, what is a “definitive contract”?
A) A contract with firm commitments from both parties
B) A contract that is awarded only to small businesses
C) A contract used exclusively for construction projects
D) A contract that cannot be modified
Answer: A) A contract with firm commitments from both parties
Explanation: A definitive contract clearly outlines the terms, obligations, and deliverables for both parties.
125. What does the Prompt Payment Act require federal agencies to do?
A) Pay contractors in a timely manner and apply interest on late payments
B) Only make payments after contract completion
C) Award all contracts within 30 days
D) Allow contractors to request early payment for all invoices
Answer: A) Pay contractors in a timely manner and apply interest on late payments
Explanation: The Prompt Payment Act ensures timely payments to contractors and establishes interest penalties for delays.
126. What is an “unsolicited proposal” in federal contracting?
A) A proposal submitted by a vendor without a formal solicitation from the government
B) A contract bid submitted after the deadline
C) A government-initiated contract request
D) A bid protest filed by a losing contractor
Answer: A) A proposal submitted by a vendor without a formal solicitation from the government
Explanation: Unsolicited proposals provide innovative ideas for government consideration outside the competitive process.
127. Which FAR clause requires contractors to disclose credible evidence of fraud or violations of federal law?
A) Contractor Code of Business Ethics and Conduct
B) Buy American Act
C) Competition in Contracting Act
D) Trade Agreements Act
Answer: A) Contractor Code of Business Ethics and Conduct
Explanation: This clause mandates disclosure of fraud or misconduct affecting federal contracts.
128. What is the purpose of a “termination for convenience” clause?
A) To allow the government to end a contract when it is in its best interest
B) To require contractors to complete all work regardless of circumstances
C) To prevent contract modifications
D) To ensure contracts are only terminated for default
Answer: A) To allow the government to end a contract when it is in its best interest
Explanation: This clause enables the government to terminate contracts without contractor fault.
129. What does the Contract Disputes Act (CDA) require contractors to do before filing a lawsuit?
A) Submit a written claim to the Contracting Officer for resolution
B) File a bid protest
C) Request arbitration with the SBA
D) Seek a waiver from the Department of Justice
Answer: A) Submit a written claim to the Contracting Officer for resolution
Explanation: The CDA requires contractors to submit disputes to the Contracting Officer before pursuing legal action.
130. What is the “Limitation of Funds” clause in cost-reimbursement contracts?
A) It prevents the contractor from exceeding allocated funds without government approval
B) It requires agencies to fully fund all contracts at award
C) It guarantees automatic reimbursement of all costs
D) It limits the government’s liability in contract disputes
Answer: A) It prevents the contractor from exceeding allocated funds without government approval
Explanation: This clause ensures cost-reimbursement contracts remain within approved funding limits.
131. What is the purpose of the Service Contract Act (SCA)?
A) To establish wage and benefit requirements for service employees on federal contracts
B) To regulate construction labor wages
C) To mandate the use of only U.S.-made products in contracts
D) To prevent the outsourcing of federal jobs
Answer: A) To establish wage and benefit requirements for service employees on federal contracts
Explanation: The SCA ensures fair wages and benefits for service employees working under federal contracts.
132. Which government agency is responsible for suspending and debarring contractors?
A) The agency’s Suspension and Debarment Official (SDO)
B) The U.S. Supreme Court
C) The Department of Commerce
D) The General Services Administration (GSA)
Answer: A) The agency’s Suspension and Debarment Official (SDO)
Explanation: Each federal agency has an SDO responsible for taking suspension and debarment actions