A Comparative Analysis of FAR Part 13 vs. FAR Part 15 in the Procurement of Commercial Items in Government Contracting

Abstract

This study examines why Mission and Installation Contracting Command (MICC) contracting officers underutilize Simplified Acquisition Procedures (SAP) under Federal Acquisition Regulation (FAR) 13.5 for commercial item acquisitions up to $7.5 million—despite the regulation’s intent to streamline procurement. Through qualitative interviews and analysis of internal award data, the research explores how risk aversion, inconsistent training, and internal stakeholder influence (e.g., legal advisors, procurement analysts, small business specialists) affect decision-making. Findings reveal that many officers avoid SAP due to perceived audit risks and a lack of leadership support, defaulting instead to the more burdensome FAR Part 15. Organizational culture and local precedent further shape method selection, often discouraging use of legally permissible flexibilities. This behavior slows acquisition timelines, increases administrative workload, and limits operational responsiveness. The study offers recommendations to improve SAP utilization, including targeted training, clearer policy guidance, and stronger leadership endorsement. By addressing both technical and cultural barriers, this research supports broader acquisition reform efforts aimed at increasing efficiency and empowering the acquisition workforce.