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Verson 1, June 2026
PLA Paired-Proposal Procedure. Each offeror must submit a PLA Price Proposal with a completed Contract Price Form. The PLA must meet RFO FAR 22.502-2(b) and FAR provision 52.222-33 and clause 52.222-34.
Offerors may, but are not required to, submit a Non-PLA Price Proposal for the same scope of work.
The two proposals must be identical except for the PLA and its direct effects on cost, schedule, or technical approach.
Offerors that do not submit a PLA Price Proposal are ineligible for award.
If the offer including the PLA is the best value, GSA will award at the offeror’s proposed price.
If an offer not including a PLA is the best value, GSA will award at the offeror’s non-PLA price without FAR provision 52.222-33 and clause 52.222-34 included in the contract.
Prior to making a best value determination, GSA will determine whether the price premium for use of a PLA is reasonable.
If the price premium is reasonable, the evaluated PLA price will be used in the best value tradeoff.
Because the evaluated price already considers the value of PLAs, no further credit will be given in the cost-technical tradeoff.
The evaluated PLA price will be calculated by reducing the proposed PLA price by the lesser of 10% or $15 million.
PLA price premiums in excess of the lesser of 10% or $15 million may be found non-reasonable.
If the price premium is not reasonable, the non-PLA price will be used in the best value tradeoff.
Shown below are examples of how the PLA Paired-Proposal Procedure will be applied.
| Offeror | PLA Proposed | Reduction Applied | PLA Evaluated | Non-PLA Proposed | Tradeoff Price | Comment |
|---|---|---|---|---|---|---|
| A | $140,000,000 | 10% ($14,000,000) | $126,000,000 | $127,000,000 | PLA Price $126,000,000 | Evaluated price reduced 10%. PLA price used. |
| B | $160,000,000 | $15,000,000 | $145,000,000 | $155,000,000 | PLA price $145,000,000 | A 10% reduction would be $16 million. Reduction capped at $15 million. PLA price used. |
| C | $200,000,000 | $15,000,000 | $185,000,000 | $150,000,000 | $150,000,000 | Premium for PLA is not reasonable. Non-PLA price used. |
| D | - | - | - | $138,000,000 | Not eligible | Did not propose a PLA price. |
The example below shows how the price evaluation works under the PLA Paired-Proposal Procedure.
For each offeror, GSA reduces the PLA proposed price by the lesser of 10% or $15 million to get the PLA evaluated price.
GSA then compares the PLA evaluated price to the offeror’s Non-PLA proposed price. If the PLA evaluated price is lower or equal to the Non-PLA proposed price, the PLA proposal proceeds to the tradeoff. If the PLA price proposal is higher, the contracting officer may determine the premium is not reasonable and advance the Non-PLA price proposal to the tradeoff.
The best value tradeoff uses evaluated prices. The award is made at the proposed price.
| Offeror | PLA Proposed | Reduction Applied | PLA Evaluated | Non-PLA Proposed | Tradeoff Price | Comment |
|---|---|---|---|---|---|---|
| A | $140,000,000 | 10% ($14,000,000) | $126,000,000 | $127,000,000 | PLA Price $126,000,000 | Evaluated price reduced 10%. PLA price used. |
| B | $160,000,000 | $15,000,000 | $145,000,000 | $155,000,000 | PLA price $145,000,000 | A 10% reduction would be $16 million. Reduction capped at $15 million. PLA price used. |
| C | $200,000,000 | $15,000,000 | $185,000,000 | $150,000,000 | $150,000,000 | A 10% reduction would be $20 million. Reduction capped at $15 million. Premium for PLA is not reasonable. Non-PLA price used. |
| D | - | - | - | $138,000,000 | Not eligible | Did not propose a PLA price. |
The paired-proposal procedure is an efficient way to determine whether a PLA is fair and reasonable for a specific project. The paired-proposal procedure is used on a large-scale construction project where inclusive market research shows that two or more qualified offerors are expected to compete. Under this process, the CO lets the market answer the price reasonableness question.
Each offeror prices the same scope with a PLA and, if it chooses, without a PLA.
Each offeror’s PLA price is compared to that same offeror’s Non-PLA price. If the PLA evaluated price is less than or equal to the Non-PLA proposed price, the PLA proposal proceeds to the best value tradeoff.
If the premium for a PLA exceeds 10% or $15 million, the CO may determine the premium is excessive and advance the Non-PLA price. If the offeror submitted only a PLA proposal, the CO skips this step.
When conducting the best value tradeoff process, use the evaluated prices. The best value decision under RFO FAR 15.103-1 produces the award. In markets where qualified offerors compete with reasonable PLA pricing, PLAs win on best value. In markets where PLA proposals are not reasonable, a Non-PLA proposal may win instead.
In issuing the Executive Order requiring Project Labor Agreements, the President found that PLAs advance economy and efficiency in Federal procurement. As such, it is reasonable and appropriate to pay a premium for offers containing PLAs.
If the premium is excessive, it will not result in fair and reasonable pricing.
If the premium reaches either 10% or $15,000,000, it raises concerns. The contracting officer may conclude such a premium is excessive and substitute a lower non-PLA price.
Keep PLA out of non-price factors. Under this procedure, PLA compliance is handled entirely through price evaluation. The PLA must not be a separately weighted non-price evaluation factor in the solicitation. Awarding non-price points for PLA presence counts the same factor twice.
Separate the Technical Evaluation Team (TET) role from the CO’s role. The TET conducts the technical evaluation and ranking. The CO must calculate the PLA evaluated price, make the fair and reasonable price determination, and conduct the best value tradeoff.
Evaluate non-price factors identically for PLA and Non-PLA proposals. A Non-PLA proposal does not lose technical credit for being Non-PLA. A PLA proposal does not gain technical credit for being PLA. The technical evaluation is blind to the PLA/Non-PLA distinction.
Make the tradeoff on evaluated prices; award at proposed prices. The tradeoff is a standard RFO FAR 15.103-1 best value decision, run on the evaluated price of each proposal that proceeded from the offerors. Award is made at the selected offeror’s actual proposed price.
Document the tradeoff the same way as any other source selection. Where a higher-priced proposal is selected, document how much additional cost GSA is willing to pay for the higher-rated non-price performance, and tie the technical strengths of that offeror to specific performance benefits or risk reductions, not generalized summaries. This standard applies whether the selected proposal is PLA or Non-PLA.
Post-award clause flow-down. If award is made on a Non-PLA proposal, FAR provision 52.222-33 and FAR clause 52.222-34 do not apply and must not appear in the awarded contract. The CO reports the award to the SPE.
The Source Selection Decision Document must capture, in addition to the standard tradeoff content, the elements specific to the paired-proposal procedure:
Sample award decision language. The following language can be adapted to fit the structure of the award decision:
PLA Paired-Proposal Evaluation. GSA conducted the paired-proposal procedure established in Acquisition Letter MV-2026-03. Each offeror was required to submit a PLA proposal and permitted to submit a Non-PLA proposal for the same scope of work. For each offeror, GSA calculated a PLA evaluated price by reducing the PLA proposed price by the lesser of 10 percent or $15 million. GSA then compared the PLA evaluated price to the offeror’s Non-PLA proposed price to determine which would proceed, and determined whether prices were fair and reasonable.
[Include the per-offeror price evaluation table.]
Each offeror’s proceeding proposal (PLA or Non-PLA) was evaluated against the non-price factors and ranked in the tradeoff using the evaluated price. The award is made at the actual proposed price.
For a Non-PLA selection, include language confirming:
The paired-proposal record satisfies the documentation required by Executive Order 14063 and Office of Management and Budget Memorandum M-25-29. FAR provision 52.222-33 and clause 52.222-34 do not apply to this contract.
Upon award of a large-scale construction project using the paired-proposal procedure, contracting officers must report the following information to the PLA Tracker.
[1] A reasonable PLA premium does not, on its own, mean the PLA proposal will be selected for award. The PLA evaluated price competes in the best value tradeoff with the prices from other offerors, and the tradeoff determines best value.
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