Position Paper

Job Order Contracting Construction Assemblies Should Not Be Used in Final JOC Proposals

1. Executive Summary

Job Order Contracting (JOC) is a specialized Indefinite-Delivery, Indefinite-Quantity (IDIQ) procurement method designed to deliver efficiency, transparency, and cost predictability for facility repair, alteration, renovation, and minor construction. The foundational mechanism of JOC is the Unit Price Book (UPB) or Construction Task Catalog (CTC), which contains thousands of preset, granular, individual construction tasks (U.S. Army Corps of Engineers, 1997; Gordian, 2025).

Recently, a troubling trend has emerged whereby contractors attempt to utilize composite "systems" or "construction assemblies” within final JOC proposals. This position paper establishes that the use of multi-component assemblies in final JOC proposals is fundamentally inconsistent with the principles of JOC procurement. Owner agencies should require discreet, individual unit price line items to maintain fiduciary oversight, regulatory compliance, competitive integrity, and contractual transparency (FAR Parts 16 and 36).

2. Statement of the Issue

Construction assemblies consolidate multiple discrete components into a single composite price (for example, pricing an entire exterior wall per square foot rather than separately pricing framing, insulation, gypsum board, fasteners, joint treatment, and finishes).

Assemblies are valuable during conceptual estimating and early budgeting (AACE International, 2020). However, their inclusion within a final JOC Job Order Proposal masks detailed quantities and individual construction tasks.

This lack of transparency conflicts with the fundamental operating principles of JOC, where contractors are expected to apply their competitively bid coefficient to predefined, individual unit prices contained within the contract UPB (USACE, 1997).

3. Core Technical Arguments Against Assemblies in JOC

A. Violation of the Granular Detail Requirement

The integrity of a JOC program depends upon exact scope verification. Final proposals should directly correspond to measurable work in the field.

When contractors substitute construction assemblies for individual UPB items, they eliminate the visibility necessary for owners to independently verify quantities and scope.

For example, constructing a partition wall should identify individual quantities of:

• metal studs
• track
• gypsum board
• insulation
• screws
• tape
• joint compound
• paint
• accessories

rather than one generalized "wall assembly."

This detailed approach supports accurate field verification, change management, maintenance history, and future facility asset management (APPA, 2022).

B. Undermining the Competitively Bid Coefficient

The competitive element of JOC is the contractor's Adjustment Factor (Coefficient), which is applied uniformly to every predefined UPB task.

Because the unit prices are fixed before bidding, every contractor competes using exactly the same baseline pricing structure (USACE, 1997).

Construction assemblies often include generalized assumptions regarding:

• waste
• productivity
• miscellaneous fasteners
• cleanup
• incidental equipment
• labor overlap

These embedded assumptions vary between contractors and cannot be independently verified.

Consequently, applying a coefficient to a generalized assembly effectively applies the contractor's markup to hidden variables rather than to competitively established unit prices, reducing pricing transparency and diminishing the intent of the original competition.

C. Reduced Auditability and Fiduciary Accountability

Public agencies have an obligation to demonstrate that every dollar spent corresponds to measurable work completed.

Government Accountability Office (GAO) guidance consistently emphasizes documentation sufficient to permit independent verification of expenditures (GAO, 2023).

Likewise, the Office of Management and Budget (OMB Uniform Guidance, 2 CFR Part 200) requires costs charged to federally funded projects to be:

• necessary
• reasonable
• allocable
• adequately documented

Composite assemblies make it significantly more difficult to verify:

• quantities installed
• duplicate charges
• omitted components
• hidden markups
• embedded assumptions

Granular UPB pricing provides a transparent audit trail that substantially improves financial accountability.

4. Regulatory and Framework Compliance Analysis

FAR Context

Although the Federal Acquisition Regulation (FAR) does not expressly prohibit construction assemblies, multiple FAR provisions strongly support the use of discrete, measurable unit prices.

FAR Part 16 — Indefinite-Delivery Contracts

FAR 16.504 establishes the framework for IDIQ contracting.

JOC relies upon predetermined unit prices that become firm-fixed when multiplied by measured quantities and the contractor's competitively bid coefficient.

Individual UPB tasks satisfy this objective far better than generalized assemblies.

FAR Part 36 — Construction Contracting

FAR Part 36 emphasizes measurable construction work, proper estimating, and contract administration.

Detailed line-item pricing facilitates:

• equitable adjustments
• inspection
• payment verification
• change order negotiation
• contract closeout

These objectives become considerably more difficult when composite pricing obscures individual construction activities.

Cost Documentation

Federal acquisition policy requires sufficient cost documentation to support pricing decisions (FAR 15.404-1).

Although JOC proposals are not traditional negotiated procurements under FAR Part 15, the same principles of transparency, reasonableness, and documentation apply during proposal review.

Non-Prepriced Work (NPP)

Most federal and state JOC contracts establish limits on Non-Prepriced (NPP) work.

If contractors routinely replace pre-priced UPB items with proprietary assemblies, the practical effect is to bypass the competitively established UPB and increase reliance on NPP pricing, potentially exceeding contractual thresholds established by the owner.

5. Definitive Position and Enforcement Guidance

Position

Multi-component construction assemblies and broad system pricing should not be used within final JOC Job Order Proposals.

Instead, contractors should prepare final proposals using only individual UPB tasks contained within the approved contract Unit Price Book or Construction Task Catalog.

This approach preserves:

• transparency
• competition
• auditability
• quantity verification
• change management
• owner confidence

Recommended Enforcement Practices

Owner agencies should:

• Reject proposals containing composite assemblies or lump-sum system pricing.
• Require every construction activity to be represented by measurable UPB line items.
• Verify that no macro assemblies duplicate individual tasks.
• Require contractors to convert conceptual assemblies into detailed quantity takeoffs before proposal approval.
• Limit use of Non-Prepriced work to the circumstances permitted by the contract.

6. Conclusion

The strength of Job Order Contracting lies in its transparency.

Its competitive pricing model depends upon contractors applying a single competitively bid coefficient to thousands of predefined, measurable construction tasks.

Allowing generalized construction assemblies into final proposals weakens transparency, complicates auditing, reduces owner oversight, and undermines one of the principal advantages of the JOC procurement methodology.

Owners that consistently require detailed UPB pricing better protect public funds, improve contract administration, simplify audits, and preserve the integrity of their JOC programs.

References

AACE International (2020) Recommended Practice No. 18R-97: Cost Estimate Classification System. Morgantown, WV: AACE International.

APPA (2022) Facilities Performance Indicators Survey. Alexandria, VA: APPA—Leadership in Educational Facilities.

Federal Acquisition Regulation (2025) 48 CFR Chapter 1. Parts 15, 16 and 36. Washington, DC: U.S. General Services Administration, Department of Defense and National Aeronautics and Space Administration.

Government Accountability Office (GAO) (2023) Standards for Internal Control in the Federal Government (Green Book). GAO-24-107295. Washington, DC: U.S. Government Accountability Office.

Gordian (2025) Job Order Contracting Overview and Construction Task Catalog (CTC) Methodology. Greenville, SC: Gordian.

Office of Management and Budget (OMB) (2024) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 2 CFR Part 200. Washington, DC: Executive Office of the President.

U.S. Army Corps of Engineers (USACE) (1997) Job Order Contracting (JOC): An Introduction for Owners. Engineering and Construction Bulletin. Washington, DC: Department of the Army.

Construction Specifications Institute (CSI) (2020) MasterFormat®. Alexandria, VA: Construction Specifications Institute.

Construction Specifications Institute (CSI) (2020) UniFormat® II. Alexandria, VA: Construction Specifications Institute.