How the Same Sole Source Gets Two Different Rule Numbers

Authentic8's Silo suite has turned up on the federal record three times this year, and each time it cost roughly an order of magnitude more than the last.

In March an Air Force shop bought it for $8,475,996.55 against six offers. In April a second buy of a related managed-attribution package went for $1,786,180.47 against four.

On Monday, Army Contracting Command at Rock Island established a Department of War enterprise vehicle for the whole suite at $307,723,563, and the board entry says one bid was solicited with one received.

So here is the question the week opens on:

"When does an agency stop competing something it has been buying competitively all year?"

The answer was published in May, and again in August

The Army noticed this twice. On May 29 Rock Island posted W519TC-26-R-SILO, a notice of intent to award a sole-source FFP IDIQ to Authentic8, pursued "under the authority of FAR 6.302-1" because the company "is the developer and sole proprietor of the SILO software."

On August 18 the same office posted PANROC-26-P-0000034775, same vendor, same enterprise scope, this time to be awarded "in accordance with Revolutionary FAR Overhaul (RFO) Federal Acquisition Regulation (FAR) 6.103-1(b), Only One Responsible Source."

Same exception. Same requirement. Two numbers, 81 days apart.

We wrote in August that DoD contracting officers had started citing the overhauled 6.103-x numbering in March and that keyword alerts on 6.302 were quietly dropping awards. This is the cleanest version of that: a single requirement that cites both, so the alert that caught the May notice had no reason to fire on the August one.