The Department of Defense still buys a large share of professional services, logistics support, and systems engineering through indefinite-delivery, indefinite-quantity vehicles. Many of those parent awards are cost-plus. Once a prime is on the vehicle, individual task orders—not the original competition—determine what is actually performed and billed.

According to public Federal Acquisition Regulation text and Defense Federal Acquisition Regulation Supplement clauses, an IDIQ establishes a ceiling and a roster of eligible contractors. Delivery or task orders then specify the work. On cost-plus fixed-fee and cost-plus award-fee orders, the government reimburses allowable costs and pays a fee. The government’s incentive to control scope is weaker than on a firm-fixed-price buy.

Government Accountability Office bid-protest decisions and DoD Inspector General audits have, for years, described cases in which the contractor that already holds the IDIQ seat is asked to draft, or is allowed to heavily mark up, the performance work statement for the next order. The record in those files typically shows government officials remaining the signing authority. The language of the order often originates with the firm that will perform it.

FAR Subpart 9.5 treats organizational conflicts of interest as a matter of impaired objectivity: a contractor that helps define requirements may later evaluate or perform against those same requirements. Contracting officers are directed to avoid, neutralize, or mitigate such conflicts. Public protest dockets show that mitigation sometimes consists of a firewall memo, a recusal of named personnel, or a government “technical review” of contractor-drafted text. Protesters have argued that those steps do not restore a genuine government-written requirement.

Named institutions appear repeatedly in the public record. The Army Contracting Command, Naval Sea Systems Command, Air Force Life Cycle Management Center, and Defense Information Systems Agency have all issued multiple-award IDIQs for advisory and assistance services, systems engineering and technical assistance, and information-technology support. Parent contracts in those families are routinely cost-reimbursable at the task-order level. USASpending.gov and FPDS extracts show billions of dollars obligated each year against such vehicles without a new full-and-open competition for each order.

A 2010s-era series of DoD IG reports on services acquisition found that statements of work were frequently incomplete at the time of order award and were later refined with contractor input. The same reports noted that cost-plus structures made growth in labor hours and other direct costs relatively easy to accommodate once the order was in place. Later IG summaries of contingency and CONUS support contracts described similar drafting practices on logistics IDIQs.

Congress has not banned contractor assistance in requirements development. The Services Acquisition Reform Act era and subsequent NDAA provisions directed better definition of requirements and more use of performance-based language. They did not prohibit a winning prime from submitting a draft PWS when the government requested technical assistance under an existing order or under a separate “acquisition support” line.

Industry associations have publicly argued that early contractor involvement improves technical accuracy and schedule realism. DoD officials, in published acquisition guides, have said that the government must retain control of the requirement and of independent cost estimates. Those two positions sit side by side in the same policy manuals.

The mechanics are straightforward. After a fair-opportunity notice on a multiple-award IDIQ, the selected prime may be issued a small “planning” or “transition” task. That task’s deliverable is often a draft statement of work, a labor mix, and a cost-plus proposal for a larger follow-on order. The larger order is then awarded to the same prime, sometimes on a sole-source or limited-competition basis justified by urgency, unique qualifications, or the parent contract’s ordering procedures.

Public protest decisions from the GAO have sustained challenges where the agency could not show that it independently developed the requirement or that other IDIQ holders had a fair chance to shape the work. Other protests have been denied where the file contained a government-authored “final” PWS even if an earlier draft came from industry. The distinction is documentary. It is not always visible in the award notice.

Cost-plus IDIQ task orders also interact with the Truthful Cost or Pricing Data statute and with DCAA audit rights. When the order is not based on adequate price competition, certified cost or pricing data may be required. Audits then examine incurred costs after the fact. They do not, by themselves, rewrite a statement of work that the performer helped compose.

Revolving-door statistics published by the Office of the Inspector General and by private watchdogs show former program officials joining the same primes that hold the relevant IDIQs. Ethics rules impose cooling-off periods for certain representations. They do not, on the public record, bar a former official’s new employer from drafting a PWS for a vehicle the official once oversaw, provided recusals are on file.

Budget justification books submitted to the congressional defense committees list IDIQ vehicles as acquisition strategies for research, development, test, and evaluation as well as for operation and maintenance. Those books do not itemize which task-order PWSs were contractor-drafted. Obligation data show the dollars. They do not show the authorship of the paragraphs that justified the dollars.

The practice is not unique to one service or one decade. Similar patterns appear in civilian agency OASIS and Alliant-style vehicles that DoD activities sometimes use. The common element is a cost-reimbursable order on a pre-competed IDIQ, with the incumbent or recent winner supplying the text that defines the next increment of work.

Oversight bodies have recommended that contracting officers document independent government estimates before reviewing contractor drafts, that they use performance-based metrics rather than labor-hour descriptions, and that they compete orders more often among IDIQ holders. Implementation, according to subsequent IG follow-up reports, has been uneven.

Nothing in the open docket establishes that every cost-plus IDIQ task order is ghostwritten by the prime. The files that have been reviewed in audits and protests show that the pattern is frequent enough to be treated as a known acquisition risk rather than an anomaly. The regulations remain the same. The vehicles remain in use. The task orders continue to be written, awarded, and billed.