Bridge Contracts: Justification, Approval, and Pitfalls

A bridge contract is a short-term, usually noncompetitive agreement that keeps an incumbent contractor performing when an existing contract expires before its competitive replacement is ready. The Government Accountability Office describes it as either an extension beyond a contract’s performance period (including option years) or a new sole-source award to the incumbent to prevent a service lapse.¹ The FAR contains no government-wide definition and the Office of Federal Procurement Policy has not issued standardized guidance, so contracting officers have to assemble the legal basis, approvals, and documentation from several overlapping authorities.

Why Agencies End Up Needing One

The most common cause is not an emergency. It is late acquisition planning. Program offices deliver statements of work, independent cost estimates, and supporting documents late or with errors, the follow-on solicitation slips, the incumbent contract runs out, and the agency has a gap to fill. A GAO review found that these planning failures, not urgent events, account for the majority of bridge contracts across federal agencies.¹

Bid protests are the other frequent driver. When a losing offeror challenges an award, federal law generally prohibits the agency from proceeding with the new contract while the protest is pending.² GAO must resolve a protest within 100 calendar days, and that clock can effectively restart as a protest moves through stages.³ During the freeze, the incumbent has to keep working, which usually means a bridge. Experienced contracting officers build a protest contingency into their acquisition timelines for exactly this reason.

The Two Legal Paths

Not every bridge is structured the same way, and the mechanism you pick determines which regulations apply, who has to approve, and how much documentation you owe.

Extending Under the Option to Extend Services Clause

If the expiring contract contains an Option to Extend Services clause, the contracting officer can extend performance for up to six months total at the existing contract rates, with adjustments limited to revised Department of Labor prevailing wage rates.⁴ This is the cleanest bridge mechanism because the option itself was competed as part of the original award. The contracting officer still has to confirm funds are available, the requirement continues, exercising the option is the most advantageous method of filling the need, and the contractor’s performance has been acceptable.⁵

Awarding a New Sole-Source Contract

If no option clause is available, or the six months have already been used, the agency has to award a new contract on a sole-source basis. That triggers the full justification and approval regime under FAR Part 6, including a written determination that full and open competition is not feasible.⁶ Some agency supplements treat sole-source bridge contracts as independent acquisitions that cannot be executed by simply modifying the predecessor. Under those rules, the contracting officer issues a separate contract with its own terms, clauses, and compliance documentation rather than incorporating the old contract by reference.⁷

Duration and Pricing Realities

Bridges are typically planned for six months or less. In practice they run longer. In one GAO sample of 29 bridge contracts, more than half exceeded six months once follow-on extensions were stacked, and six ran longer than three years. An Army bridge for computer support that was scoped as a 12-month gap-filler ultimately spanned 42 months.⁸ Serial extensions are the single biggest risk in bridge contracting because each new increment looks reasonable in isolation while the cumulative period quietly removes competition for years.

When a bridge is justified under the unusual and compelling urgency authority, the total performance period cannot exceed one year unless the agency head makes a written determination that exceptional circumstances apply.⁹ Any extension past that year under the same authority requires a separate determination at the same level. This is one of the few hard duration limits in the FAR.

Scope during a bridge should mirror the predecessor contract. Adding tasks on a noncompetitive contract raises costs and erodes the rationale for skipping competition. At least one major contracting activity responded by issuing an internal policy prohibiting scope expansions on bridges and building a tracking system to enforce it.⁸

Pricing usually starts from the predecessor’s rates, and contracting officers lean on historical prices to support their fair-and-reasonable determination. Rates do not always hold, though. GAO found that in half the bridge contracts it analyzed for pricing, rates went up. One Navy bridge for IT support saw a 6.4 percent monthly rate increase.⁸ With competition absent, the buyer’s leverage is weak, and the analysis usually amounts to comparison against what the agency was already paying.

Justification and Approval

A sole-source bridge requires a written Justification and Approval under FAR 6.303. The J&A must contain twelve categories of information. The consequential ones for bridge work are the description of the supplies or services with an estimated value, the statutory authority permitting noncompetitive award, the demonstration of the contractor’s unique qualifications, the fair-and-reasonable cost determination, and the description of market research conducted.¹⁰ The J&A also has to describe what the agency will do to restore competition for future acquisitions, which is the paperwork expression of the idea that a bridge is supposed to be temporary.

Two statutory authorities cover most bridge scenarios. The first, only one responsible source, applies to follow-on contracts where awarding to a different contractor would cause substantial duplication of cost or unacceptable delays.¹¹ The second, unusual and compelling urgency, applies when the government would be seriously injured by delay.⁹ The choice matters because it drives the allowable performance period and the narrative structure of the justification.

Approval Thresholds by Dollar Value

Who signs the J&A depends on the total value, including the estimated value of all options:

Up to $900,000: the contracting officer’s own certification is sufficient unless agency procedures require higher approval.
Over $900,000 up to $20 million: the competition advocate for the procuring activity must approve, and that authority cannot be delegated.
Over $20 million up to $90 million ($150 million for DoD, NASA, and the Coast Guard): the head of the procuring activity or a senior designee must approve.
Over $90 million ($150 million for DoD, NASA, and the Coast Guard): the agency’s senior procurement executive must approve, and that authority is generally non-delegable.¹²

Individual agencies often layer additional approval requirements on top of the FAR baseline. The Navy, for example, uses a three-tier system with sign-off levels at $700,000, $5.5 million, and above $5.5 million.¹³ Check the applicable agency supplement before assuming the FAR thresholds are the whole story.

Wage Determinations and Bonds

Service bridges frequently trigger obligations under the Service Contract Labor Standards. When a contract extension or modification takes the value above $2,500 and either extends the period of performance or significantly changes the labor scope, the contracting officer has to obtain a current wage determination from the Department of Labor.¹⁴ This catches a lot of bridges because the predecessor’s wage determination may be years old and prevailing rates may have moved. Workers performing under the bridge are entitled to current prevailing wages regardless of what’s baked into the paperwork, so treating the bridge as a routine paperwork exercise creates real compliance exposure.

Construction bridges have a parallel issue with bonds. Existing performance and payment bonds do not automatically extend to cover the bridge period. If the contract price increases, the government may require the contractor to increase the bond amount or obtain an additional bond, typically equal to the full amount of the price increase.¹⁵ Service contracts may carry analogous insurance requirements. Gaps here leave the government exposed if the contractor defaults mid-bridge.

Where Bridge Contracts Get Agencies in Trouble

Bridges attract scrutiny because they bypass competition. GAO has repeatedly flagged that frequent or prolonged use exposes the government to overpaying for services that could be obtained more cheaply through competition.¹ The absence of a government-wide definition makes the pattern hard to see from inside an agency. Because individual J&A documents do not always disclose prior bridges for the same requirement, approving officials sometimes sign off on what looks like a short-term extension without recognizing it as the third or fourth in a row.

Poorly justified bridges also lose protests. Interested vendors can challenge the award at GAO or the Court of Federal Claims, and those challenges have succeeded where the agency’s sole-source rationale rested on its own staffing shortages or its failure to prioritize procurement work. Poor planning is not the kind of unusual and compelling circumstance the statute contemplates. Some agency-level policies now require the J&A to affirmatively demonstrate that the need for a bridge did not result from a lack of advance planning.⁷

Funding is the third exposure. Federal agencies cannot obligate funds they do not have, and a bridge awarded during uncertain appropriations can collide with the Anti-Deficiency Act’s prohibition on obligating in advance or in excess of available appropriations. During a lapse, only activities covered by available multi-year or no-year funds, or those necessary to protect human life and government property, may continue. A bridge that assumes stable funding when the appropriation is about to expire needs coordination with the agency’s budget office before it’s signed.

Ending the Bridge Cleanly

The bridge’s reason for existing disappears the moment the competitive follow-on is awarded and signed. Build the transition around a ramp-down window where the incumbent finishes in-progress work while the new contractor mobilizes, and make data transfers, asset handoffs, and knowledge-sharing part of that overlap rather than an afterthought.

Watch for overlapping performance periods that could lead to paying two contractors for the same work. The bridge should include a termination or expiration mechanism tied to the follow-on contract’s start date rather than a fixed calendar date, so the bridge doesn’t outlive its purpose on paper. Once final invoices clear and the performance period closes, the bridge is archived in the contract file and the requirement returns to a competitive footing.

1
U.S. Government Accountability Office. Information Technology – Agencies Need Better Information on the Use of Noncompetitive and Bridge Contracts
2
Office of the Law Revision Counsel. 31 USC 3553
3
U.S. Government Accountability Office. Bid Protests FAQs
4
Acquisition.GOV. FAR 52.217-8 Option to Extend Services
5
Acquisition.GOV. FAR 17.207 Exercise of Options
6
Acquisition.GOV. FAR 6.302 Circumstances Permitting Other Than Full and Open Competition
7
Acquisition.GOV. DLAD Part 16 Types of Contracts
8
U.S. Government Accountability Office. Sole Source Contracting – Defining and Tracking Bridge Contracts Would Help Agencies Manage Their Use
9
Acquisition.GOV. FAR 6.302-2 Unusual and Compelling Urgency
10
Acquisition.GOV. FAR 6.303-2 Content
11
Acquisition.GOV. FAR 6.302-1 Only One Responsible Source and No Other Supplies or Services
12
Acquisition.GOV. FAR 6.304 Approval of the Justification
13
Acquisition.GOV. NMCARS Annex 5 Bridge Contract Approval and Reporting
14
Acquisition.GOV. FAR 22.1007 Requirement to Obtain Wage Determinations
15
Acquisition.GOV. FAR 52.228-15 Performance and Payment Bonds Construction