Section L vs Section M: how to read an RFP's instructions and evaluation factors

If you bid on federal work, you will hear proposal people say "L and M" the way contractors say "plans and specs". Two sections of a long document decide most of what you write, how you write it and where you spend your effort. This guide explains what each one is, how they differ, and how to read them side by side.

Where L and M sit

Federal negotiated solicitations (FAR Part 15) are normally built in the uniform contract format, which has 13 lettered sections, A through M (FAR 15.204-1). They fall into four parts:

Sections L and M are in Part IV for a reason. They aren't about the contract you will perform. They are about the competition you are in right now.

What Section L does

Section L is titled "Instructions, conditions, and notices to offerors or respondents." Under FAR 15.204-5(b), it holds the provisions and guidance that help you prepare a proposal, and it may set out how the proposal is organized into parts: administrative, management, technical, past performance and price.

In practice, Section L is where you find:

• The volumes. How many, what they are called, and what goes in each.
• Page limits. And what is excluded from them: cover pages, resumes, tables of contents, past performance forms.
• Format rules. Font, size, margins, line spacing, page size, file type, file naming.
• How and where to submit. An email address, a portal, SAM.gov, an agency system, or a physical address. The due date and time zone.
• Content instructions. "Describe your approach to...", "Provide three references...", "Identify key personnel..."
• How to ask questions, and the date they are due.
• Rules about amendments, late proposals, proprietary markings and oral presentations.

Section L is mostly pass/fail. If L says the technical volume is limited to 20 pages and yours is 24, the contracting officer may not read page 21 onward, or may rule the proposal noncompliant. A missed L instruction is rarely about quality. It is about whether your proposal gets evaluated fairly, or at all.

What Section M does

Section M is titled "Evaluation factors for award." It must identify all the significant factors and subfactors the government will consider in awarding the contract, and their relative importance (FAR 15.204-5(c), FAR 15.304(d)).

Section M tells you:

• The factors and subfactors. Typically technical approach, management approach, past performance, key personnel and price.
• Their relative importance. Equal, or listed in descending order, or weighted by points.
• How the factors compare with price. The solicitation has to say whether the non-price factors combined are significantly more important than, approximately equal to, or significantly less important than price (FAR 15.304(e)).
• The basis of award. Best value tradeoff or lowest price technically acceptable.
• The rating method, if the agency chooses to share it. It doesn't have to (FAR 15.304(d)).

M is where you learn what the agency values. L tells you what goes on the page. M tells you what earns the points.

The two basis-of-award models

The basis of award in Section M changes how you bid more than anything else in it.

Best value tradeoff (FAR 15.101-1). The agency may pay more for a proposal that is better. The solicitation lists the factors and subfactors, their relative importance, and how the non-price factors weigh against price. If technical merit is "significantly more important than price," you win on quality. A strong, specific, well-evidenced proposal is worth a premium.

Lowest price technically acceptable, or LPTA (FAR 15.101-2). Award goes to the lowest evaluated price among proposals that meet or exceed the acceptability standards for the non-price factors. Tradeoffs aren't allowed, and proposals aren't ranked on the non-price factors. Here the non-price factors are pass/fail gates, so your job is to meet every standard clearly and then price sharply. Extra quality isn't rewarded.

Read the first paragraph of Section M carefully for this statement. If it is missing, or only implied, ask.

Reading L and M together

L and M are written by different people, sometimes at different times, and they don't always line up. Read them side by side, not one after the other.

1. Match the factors to the volumes. Each factor in M should have a home in L. If M scores "management approach" and L has no management volume or section, find out where the agency expects it.
2. Match the instructions to the scoring. If L asks for something M never scores, it is probably a compliance item: do it, but don't spend your best writing on it. If M scores something L never asks for, you still need to address it somewhere.
3. Check the order. Many agencies list the factors in M in descending order of importance. If L orders the volumes differently, follow L for the layout and M for where you spend effort.
4. Look for the words. "Must", "shall", "will be rejected" and "will not be considered" are L's pass/fail language. "More important than", "equal in importance" and "significantly more important" are M's weighting language.
5. Note the page budget against the weights. If a factor is worth the most and has the smallest page allowance, you have to write tightly. If it is worth little and has a large allowance, you don't have to fill it.
6. Find what counts as a "page". Whether the cover letter, resumes, charts and appendices count toward the limit is a classic place to lose a proposal.

The simplest way to do all this is a table with the factors from M down the side and the L instructions across the top. A compliance matrix (see how to build an RFP compliance matrix) is that table, kept up to date.

A worked example, in the abstract

Suppose a services RFP has three evaluation factors: technical approach, past performance and price. Section M says technical approach is more important than past performance, and past performance is more important than price, and that technical and past performance combined are significantly more important than price. Section L says the proposal has a technical volume of 15 pages, a past performance volume of up to 3 references, and a price volume with no page limit, all as PDFs by 2:00 p.m. Eastern.

What you read from this:

• The factors in descending order tell you where to spend effort: technical first, then past performance, then price.
• The 15-page limit is the constraint on the most important factor, so plan the technical volume page by page before you write.
• The three-reference limit is a compliance item and a scoring item: you pick your three best, most recent, most relevant references, and you meet the format L asks for.
• The price volume has no page limit, but it still has to follow the instructions: the pricing schedule, the labor categories and the assumptions.
• The deadline has a time zone, and the portal may close at exactly that moment.

None of this is hard. It is only easy to lose in a 60-page document at 11 p.m. on the night before the deadline.

When L and M disagree

They sometimes will. Common cases: L asks for a volume M doesn't mention, M lists a factor with no place for it in L, two different page limits appear for the same volume, or the due date differs between the solicitation form and L.

Don't pick the reading that is convenient. Do this:

1. Write down the conflict with page references.
2. Submit a written question by the deadline for questions, which is stated in L or on the solicitation form. After the solicitation is released, the contracting officer is the focal point for exchanges with potential offerors (FAR 15.201(f)), and the answer should go to everyone.
3. Watch for an amendment. When the government changes its requirements or terms, the contracting officer must amend the solicitation (FAR 15.206(a)). Check SAM.gov or the portal every day until you submit.
4. If the question isn't answered in time, follow the stricter reading, and note your assumption where the proposal allows one.

Commercial and state and local RFPs

Commercial solicitations. When an agency buys commercial products or services under FAR Part 12, the solicitation is normally assembled around an SF 1449 (FAR 12.303), with the provisions at 52.212-1 (instructions to offerors), 52.212-2 (evaluation) and 52.212-3 (representations and certifications). These do the jobs of L and M. Agencies usually add an addendum to 52.212-1 with the volumes, page limits and submission method. Read the provision and the addendum together, because the addendum can change the default text.

For example, 52.212-1 says an offer must be held firm for 30 calendar days unless the solicitation says otherwise (FAR 52.212-1(c)), and 52.212-2 requires the factors to be listed in descending order of importance (FAR 52.212-2(a)). So if you see a list there, the order carries meaning.

State, county and city RFPs. There is no uniform format. The "L" section is often called "Instructions to proposers", "Proposal format" or "Submission requirements". The "M" section may be called "Evaluation criteria", "Scoring" or "Selection process", often with points per criterion that add up to 100. The reading method is the same: separate what you must submit from how it will be scored, and read them together. Local rules also often add things federal solicitations don't, such as a required local business registration, a mandatory pre-proposal meeting or notarized forms.

A short checklist

• Is the basis of award best value or LPTA, and where does it say so?
• What are all the factors and subfactors, in what order, and how do they compare with price?
• How many volumes, with what page limits and what is excluded from the count?
• What are the format rules: font, size, margins, file type, file name?
• Where and how do I submit, by what time, in what time zone?
• When are questions due, and have I asked about each conflict?
• Which forms, certifications and registrations does L or K require?
• Is there an amendment I haven't acknowledged?

Get the matrix without the shredding

Pulling every L instruction, every M factor and every shall statement into one spreadsheet takes a day for a long RFP. FileAI's RFP compliance matrix does it from your PDFs for US$99 per RFP: every instruction, evaluation factor, form, eligibility condition and deadline, each with the quote and the page it came from. Try the free preview first, then add your owners and proposal sections.

Sources

• Federal Acquisition Regulation, 15.204-1 Uniform contract format and 15.204-5 Part IV, Representations and instructions
• FAR 15.304 Evaluation factors and significant subfactors, 15.101-1 Tradeoff process and 15.101-2 Lowest price technically acceptable source selection process
• FAR 15.201 Exchanges with industry before receipt of proposals and 15.206 Amending the solicitation
• FAR 12.303 Contract format, 52.212-1 and 52.212-2

This guide is general information, not legal or procurement advice. Always follow the instructions in the specific solicitation you're responding to. FAR text is current as of the date above; the FAR is being revised, so check acquisition.gov for the version that applies to your solicitation.