Can an Agency Screen GSA Schedule Holders by CPARS Before the RFQ? What GAO's Wilson 5 Decision Means

Yes. In Wilson 5 Service Company, Inc., B-424429 (July 17, 2026), GAO denied a protest after GSA sent a Schedule RFQ only to 16 small businesses whose CPARS category ratings were at least 99 percent Satisfactory or better. Under the FAR overhaul, an agency no longer has to hand the RFQ to every Schedule holder who asks.

I spent eighteen years in federal acquisition as a Contracting Specialist and Contracting Officer at GSA, IRS, DoD, DOI, HHS, FTC, and Energy. This decision changes where the competition starts. It now starts at market research, and your CPARS record is the ticket in.

What did GAO decide in Wilson 5 Service Company, B-424429?

GAO denied the protest. GSA's Public Buildings Service lawfully limited a complete facilities maintenance RFQ to 16 vendors picked from RFI respondents using business size, specific MAS SINs, and a CPARS threshold. Sixteen invitations were enough to reasonably expect at least three quotations, which is all the ordering rules require.

You can read the full decision on GAO's website. The key facts:

One precise point: GAO did not endorse 99 percent as a standard. It held that GSA followed the ordering rules. The threshold survived because nothing in those rules forbids it.

Why can an agency now refuse to give you the RFQ?

The Revolutionary FAR Overhaul (RFO) deleted the old FAR 8.404(f) rule that an agency must provide the RFQ to any Schedule contractor that requests it. GSA now follows the class deviation procedures in GSAR subpart 538.71, which contain no such requirement.

For a Schedule order or BPA above the simplified acquisition threshold, GSAR 538.7103-3(a) gives the ordering activity two paths:

1. Publish the RFQ on eBuy, open to every Schedule holder on the relevant SINs.
2. Issue the RFQ directly to as many FSS contractors as practicable to reasonably ensure quotations from at least three.

GAO reaffirmed that "as practicable" means enough vendors to reasonably ensure three quotes, citing its earlier decisions in Technical Professional Services (B-410640) and AtechGov (B-423738). It does not mean every capable vendor. GSA has proposed codifying these procedures through GSAR Case 2026-G501, and the proposed text keeps the at-least-three standard. Comments close October 22, 2026. I covered that rule in my breakdown of GSAR Case 2026-G501.

How did GSA's 99 percent CPARS math actually work?

GSA multiplied each vendor's CPARS assessments from January 1, 2021 forward by six category ratings, then calculated the share rated Marginal or Unsatisfactory. Any vendor above 1 percent was cut. Ten assessments equal 60 ratings, so three low ratings meant 5 percent.

Here is the part most write-ups skip. A 1 percent ceiling cannot absorb even one Marginal until you have 100 category ratings, which is about 17 assessments. For a small business with a thin CPARS file, one bad rating ends the conversation.

Notice also the five-year lookback. The FAR tells agencies to use CPARS information within three years of contract completion, but this was a vendor-pool screen, not a quotation evaluation, and GAO's decision does not discuss the window. Assume every rating in your file is live.

What does this look like from the Contracting Officer's seat?

A Contracting Officer facing 41 RFI responses and a small team needs a defensible, objective way to shrink the pool. CPARS is attractive because it is already in the system, it is numeric, and nobody can accuse the CO of picking favorites.

When I sat on the other side of the desk as a Contracting Officer, the question was never whether a vendor could do the work. It was how to document the choice so it held up. A formula applied to every respondent is exactly the kind of record that survives a protest.

As a Contracting Specialist, I read stacks of RFI responses. The ones that made the cut were short, mapped to the requirement, and stated their SINs and performance record up front. Generic capability statements went into the pile nobody reread. Expect more ordering activities to borrow this approach:

• Objective filters such as size status, exact SINs, and CPARS percentages.
• Documented pool size tied to the three-quote standard.
• Resource justification citing limited staff and time, which GAO accepted here.

How do you manage CPARS so you pass a screen like this?

Treat every CPARS evaluation as a gate, not a report card. Under RFO FAR 42.1103, you get up to 14 calendar days from notification to comment, rebut, or add information, and disagreements go to a review above the Contracting Officer. Miss the window and the rating stands without your side.

The legacy rule lived at FAR 42.1503(d). In agencies that adopted the overhaul deviation, the same rights now sit in RFO subpart 42.11. Here is the checklist I give clients:

• Register every contract representative in CPARS and keep at least two people on notifications so a vacation never burns your 14 days.
• Calculate your own percentage using GSA's formula: total assessments over five years times six, and count every Marginal and Unsatisfactory.
• Log performance evidence monthly, including deliverable dates, quality metrics, and customer emails, so a rebuttal cites facts instead of opinions.
• Ask for interim evaluations on long orders when performance is strong, since evaluations must be prepared at least annually and at completion.
• Answer any cure notice or deficiency letter in writing, because a Marginal rating is supposed to reference the management tool that notified you.
• Rebut on the rating definitions in Table 42-1. A contractor should not get below Satisfactory solely for not exceeding requirements.
• Request review above the CO when the narrative does not support the rating, and keep the tone factual.
• Check for missing evaluations on completed orders above the simplified acquisition threshold. A thin file makes one bad rating more damaging.

How do you get into the pool before the RFQ exists?

Show up in market research with the exact data the CO will filter on. In Wilson 5, the pool was built entirely from RFI respondents, so a Schedule holder who skipped the RFI never had a chance, and one who answered vaguely gave the agency no reason to keep them.

1. Monitor eBuy RFIs and SAM.gov sources-sought notices on every SIN you hold, not just RFQs.
2. Answer every relevant RFI with your contract number, SINs, size status, and a supportable CPARS statement.
3. Confirm SIN coverage matches the full scope. GSA required 561210FAC, ANCRA, and OLM together. Missing one ancillary SIN is disqualifying.
4. Request capability briefings with program offices before acquisition strategy is final, when criteria are still being written.
5. Comment on the draft requirement if the agency releases one, and point out when a proposed filter would drop the pool below meaningful competition.

Adding a missing SIN takes a modification, so do it before the RFI lands. If you are weighing whether a performance record from an affiliate helps, see my post on affiliate past performance.

Does Wilson 5 mean every Schedule buy will use a CPARS cutoff?

No. Wilson 5 establishes that a documented CPARS screen is permissible, not required. Many buyers will still post to eBuy. But once one GSA office has a protest-tested template, expect other ordering activities to reuse it on crowded requirements.

What should you do now?

• Pull your CPARS history for the last five years and calculate your below-Satisfactory percentage using GSA's formula.
• Put the 14-day comment window on a shared calendar with two responsible people.
• Audit your SINs against the full scope of your target requirements, including ancillary and OLM SINs.
• Respond to every relevant eBuy RFI and sources-sought notice with a concise, factual performance statement.
• Consider commenting on GSAR Case 2026-G501 before October 22, 2026 if direct issuance concerns you.

Across our 70+ GSA contract awards and 200+ contract holders supported after award, the firms that win orders are the ones buyers can find and justify. If you want help positioning your Schedule and performance record before the next RFI drops, talk with our federal sales team.

Frequently Asked Questions

What is the GAO decision about the 99 percent CPARS threshold?

It is Wilson 5 Service Company, Inc., B-424429, decided July 17, 2026. GAO denied a protest after GSA limited a complete facilities maintenance RFQ in Nebraska to 16 small businesses whose CPARS category ratings were at least 99 percent Satisfactory or better over five years.

Can a Schedule holder still demand a copy of an RFQ?

Not under the FAR overhaul procedures. The old FAR 8.404(f) requirement to give the RFQ to any Schedule contractor that asks was removed, and GSAR subpart 538.71 contains no replacement. GAO confirmed the agency could refuse the request.

How many vendors must an agency solicit for a Schedule order above the simplified acquisition threshold?

Under GSAR 538.7103-3(a), the agency either posts the RFQ on eBuy or issues it to as many Schedule contractors as practicable to reasonably ensure at least three quotations. GAO reads practicable as enough vendors to reasonably ensure three quotes, not every capable vendor.

How long do I have to respond to a CPARS evaluation?

You get up to 14 calendar days from the CPARS notification to submit comments, rebuttals, or additional information. Under the FAR overhaul this sits in FAR 42.1103, formerly FAR 42.1503(d). Disagreements are reviewed at a level above the Contracting Officer.

How many CPARS assessments do I need before one Marginal rating is survivable under a 99 percent screen?

Using GSA's formula of six category ratings per assessment, you need about 17 assessments, or 100 or more category ratings, before one Marginal stays under 1 percent. With 16 or fewer assessments, a single Marginal pushes you over the limit.

Did GAO approve 99 percent as a governmentwide CPARS standard?

No. GAO held that GSA followed the ordering procedures and solicited enough vendors to expect three quotations. The decision permits a documented screen like this one but does not require any agency to use it or set any particular percentage.

What can I do before an RFQ is issued to avoid being screened out?

Answer every relevant eBuy RFI and sources-sought notice with your contract number, exact SINs, size status, and a factual CPARS statement. Make sure your Schedule carries every SIN the requirement needs, including ancillary and OLM SINs, and request capability briefings while the acquisition strategy is still forming.