Verson 1, June 2026
GSA Project Labor Agreement Procedures
1. GSA PLA Paired-Proposal Procedure.
- Use. The acquisition team must use the paired-proposal procedure in this paragraph on a large-scale construction project where inclusive market research shows that two or more qualified offerors are expected to compete.
- Solicitation. For procurements using this procedure, the solicitation must —
- Require each offeror to submit a PLA proposal meeting the requirements of RFO FAR 22.502-2(b) and FAR provision 52.222-33 and clause 52.222-34. Offerors that do not submit a PLA proposal are ineligible for award;
- Permit each offeror to also submit a non-PLA proposal for the same scope of work, identical to the PLA proposal except for the presence of the PLA and any direct cost, schedule, or technical effects of that difference; and
- Describe the price evaluation method, including the price preference applied to PLA proposals under the tradeoff procedure. Include examples to show the calculation.
2. GSA PLA Tradeoff Procedure.
- General. The acquisition team must follow a tradeoff approach in accordance with RFO FAR 15.103-1.
- Existing GSA practice for major construction, is that non-price factors, when combined, are significantly more important than price, and must be evaluated identically for PLA and non-PLA proposals. The best value determination must be made using evaluated prices (adjusted).
- PLA price reasonableness determination. The contracting officer must calculate an evaluated price for each PLA proposal by reducing the PLA proposed price by the lesser of 10 percent or $15 million. For each offeror:
- If the PLA evaluated price is less than or equal to the Non-PLA proposed price, the premium may be determined reasonable, and the PLA price proposal proceeds to the best value tradeoff.
- If the PLA evaluated price is greater than the Non-PLA proposed price, the Contracting Officer may find the premium is excessive. The Non-PLA price proposal is used in the best value tradeoff.
- Determining whether the PLA premium is reasonable does not meet the requirement to determine fair and reasonable pricing [1] of the project. The Contracting Officer should use the evaluated price in the Price Analysis and resulting best value determination.
- Award. Award is made at the actual proposed price of the proposal that represents the best value. Where award is made on a non-PLA proposal, FAR provision 52.222-33 and clause 52.222-34 do not apply and should be removed from the contract. The paired-proposal record satisfies the documentation required by E.O. 14063 and OMB Memorandum M-25-29.
Sample Solicitation Language
Solicitation, Section II (add in the appropriate subsection)
Price Proposals
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.
Solicitation, Section VI — Evaluation of Offers (add in the appropriate subsection)
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.
Solicitation, Section VI — Total Evaluated Price (add in the appropriate subsection)
PLA Best Value Tradeoff Procedure.
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.
Price Evaluation Example
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. |
Endnotes
[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.