The Justification Is the Last Thing to Arrive
The Marine Corps posted its reasoning for a $1.9 billion sole-source food services award thirteen days after signing it, one day inside the FAR clock. That, plus SOCOM cutting three years off POTFF III and five other things that moved Monday.
At 3:27 Monday afternoon, the Marine Corps posted the justification for a contract it had already signed on September 1.
The award was $1,904,796,810, a single-award IDIQ, M95494-26-D-0001, to the Colorado Department of Labor and Employment for full food service at 46 mess halls and seven satellite facilities in the continental United States. We wrote up the award on September 2, when the public record held the board entry and two statutory citations and nothing else.
The reasoning showed up Monday. Redacted, and on day 13.
"How long does an agency get to explain a two-billion-dollar sole source?"
Fourteen days. FAR 6.305 says the justification "shall be made publicly available within 14 days after contract award," and reserves a 30-day window for urgency awards under FAR 6.302-2. This notice codes its authority as far5, which is SAM's tag for FAR 6.302-5, the statute-based exception. The board cited 10 USC 3204(a)(5) and 20 USC 107, the Randolph-Sheppard priority that seated a state licensing agency ahead of the incumbent caterer.
So the order of operations a capture shop actually lives with is award first, explanation second. And the gap is entirely legal.
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