Why is the FAR Matrix effective only 2.4% of the time?
Have you ever come across to Section 52.301 of the Federal Acquisition Regulation entitled “Solicitation provisions and contract clauses (Matrix)”?
If you have, you were probably excited at first because you found a quick reference to help you determine clause applicability.
But then you dug a little deeper...
…and realized that the FAR Matrix is just not a practical tool to use.
Here are the Top 3 reasons why that is the case:
Would you hire a consultant whose advice you find useful only 2.4% of the time?
That would be a very poor record to advertise, but the FAR Matrix may, theoretically, have the same effectiveness.
The biggest problem is that the Matrix categorizes clauses into too many “Optional” or “Required when Applicable” categories (called “Contract Purpose”)…
…or it doesn’t categorize clauses at all, leaving the cells completely blank.
That means that you still have to review each of them on clause-by-clause basis.
How often does that happen?
On average, per each column in the Matrix, you have, in theory, about a 97.6% chance of running into a clause that will require you to instead review it in full text, together with its prescription.
In sum, you will save more time going directly to the full text of a clause, avoiding the Matrix completely!
The FAR Matrix breaks down applicability into 22 columns, 19 of which are called the “Principle Type and/or Purpose of Contract” categories, among which:
- 10 are dedicated to the same principal category (i.e. Contract type),
- 7 are dedicated to services involving very specific work characteristics (e.g. Facilities, Dismantling and Demo, Leasing of Motor Vehicles, etc.).
- 1 is dedicated to Commercial Items, and
- 1 is dedicated to Simplified Acquisition Procedures.
This means that, of the 22 columns that you can physically fit onto 1 page, 75% are dedicated to just 1 category (Contract Type) and 7 (not very frequently searched) types of services.
That’s a lot of wasted space representing just a tiny fraction of factors that could impact the applicability of clauses and provisions to contracts and solicitations.
Vertically, the FAR Matrix doesn’t fare any better since it spans across 800 rows of data without any sorting or searching capabilities.
In sum, if you need to quickly assess, for example, if a clause applies to a sole-source contract for the work performed outside the U.S. by a small business company, the FAR Matrix will be completely useless.
There is a tool on the market today (https://farclause.com/) that assesses applicability of clauses and provisions against 150 various categories that don’t depend on a matrix-type view.
The reason why is because the tool uses a Turbotax-like guide to walk you through the process of analyzing clauses.
Just like Turbotax saves you time by allowing you to download critical information from previous returns, FARclause.com saves you time by downloading clauses directly from your document (i.e. RFP, contract, or corporate flowdowns, etc.) without the need to type any clauses into the tool.
In addition, this tool can:
- Analyze clauses for risk using categories that are commonly used by federal contractors;
- Sort clauses by Uniform Contract Format or organize them by departmental interest;
- Print them instantly in full text with prescriptions or in summary;
- Generate subcontractor flowdowns dynamically from the set of clauses that exists in your prime contract.
In conclusion, it seems like the creators of the FAR Matrix did realize that a reference tool was needed for Contracting Officers to quickly determine clause and provision applicability.
However, limited by the amount of information (e.g. columns) they could fit onto a single paperback or web page, they categorized 800+ clauses and provisions into 19 columns representing the number of categories that is:
A. Too low to perform any meaningful applicability analysis, and
B. Too high relative to the horizontal space available.
Add the amount of discretionary “contract purpose” categories that populate the cells underneath the columns, and you will end up with a tool that is effective only 2.4% of the time, making other tools, such as the FARclause.com, a more viable solution to perform a meaningful and quicker analysis.
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