VA CONTRACTORS: GENERAL (CLASS A OR B)
EXAM AND VERIFIED ANSWERS
1. A VA contracting officer issues a unilateral modification to a fixed-price construction contract
citing the 'Changes' clause. The contractor believes the modification exceeds the scope of the
contract and files a claim. Under FAR Part 43, which of the following is the most critical factor in
determining whether the modification is within scope?
A. The dollar value of the modification relative to the original contract price
B. Whether the modified work is of a type not previously performed under the contract
C. Whether the contracting officer obtained prior approval from the head of the contracting activity
D. Whether the modification was issued before completion of the original contract
Answer: B
Rationale: Under FAR 43.201, a modification is within scope if it is within the general scope of the
original contract. The key test is whether the work is of a type not previously performed; if it is, it may be
a cardinal change. Dollar value alone is not determinative. Prior approval is not required for all
modifications, and timing is not dispositive.
2. A VA contractor incurs costs for lobbying activities aimed at influencing the award of a new
contract. Under the Cost Principles in FAR Part 31, which of the following is the correct treatment
of these costs?
A. They are allowable if the lobbying is directed at the VA only
B. They are unallowable regardless of the target of the lobbying
C. They are allowable if the contractor discloses them in the cost proposal
D. They are unallowable only if the lobbying is for a contract that would exceed the simplified acquisition
threshold
Answer: B
Rationale: FAR 31.205-22 explicitly states that costs of attempting to influence the award of a federal
contract are unallowable. This prohibition applies irrespective of the agency targeted or contract value.
Disclosure does not make them allowable. The rule is absolute to prevent misuse of public funds.
3. A Class A VA contractor is performing a $20 million renovation project at a VA medical center.
The contract requires a performance bond and a payment bond. The contractor obtains a bond
from a surety that is not listed on the Department of Treasury's Circular 570. Which of the
following is the most likely consequence?
A. The bond is valid but the VA may require additional security
B. The bond is invalid and the contractor must obtain a bond from a listed surety
C. The bond is valid if the surety is licensed in the state where the project is located
D. The bond is voidable at the VA's discretion
Answer: B
Page 1
,Rationale: Under the Miller Act and VAAR 828.102, bonds on federal construction contracts exceeding $150,000 must be
issued by sureties listed on Treasury Circular 570. A bond from an unlisted surety is invalid, and the contractor risks default
if not corrected. State licensing is irrelevant for federal contracts.
4. A VA contractor encounters differing site conditions during excavation for a hospital addition.
The contract contains the Differing Site Conditions clause. The contractor notifies the contracting
officer in writing within 10 days. The CO fails to respond. Which of the following statements best
describes the contractor's rights?
A. The contractor may proceed with a constructive change and later claim additional costs
B. The contractor must stop work until the CO responds
C. The contractor may proceed but waives any claim for additional costs
D. The contractor may terminate the contract for convenience
Answer: A
Rationale: Under FAR 52.236-2, if the CO fails to respond, the contractor may proceed with the changed
work and later seek an equitable adjustment under the Changes clause. Stopping work is not required
unless directed. Continuing does not waive the claim. Termination is not appropriate unless the changes
are fundamental.
5. Which of the following best describes the 'Competition in Contracting Act' (CICA) requirement
for full and open competition in VA contracts?
A. All contracts must be awarded to the lowest-priced, technically acceptable offeror
B. All responsible sources must be permitted to compete unless an exception applies
C. Only contractors with a Class A license may compete
D. Competition is required only for contracts exceeding $1 million
Answer: B
Rationale: CICA mandates full and open competition, meaning all responsible sources may compete.
Exceptions include sole-source, urgency, etc. Lowest-priced technically acceptable is one evaluation
method, not a requirement. Class A license is a VA-specific requirement, not a CICA mandate. The
threshold for competition is lower ($150,000 for construction).
6. A contractor is performing a cost-reimbursement contract for the VA. The contractor's
accounting system is deemed inadequate by the government. Which of the following is the most
immediate consequence?
A. The contractor may continue to bill costs but must improve the system within 30 days
B. The contractor may not be reimbursed for costs incurred after the determination
C. The contractor may be terminated for default
D. The contracting officer may withhold a portion of payments until the system is corrected
Answer: D
Rationale: Under FAR 16.301-3, if the accounting system is inadequate, the CO may withhold payments
up to 10% or more until the system is corrected. Reimbursement may continue subject to withholding.
Termination for default is not immediate; the contractor is given an opportunity to cure.
Page 2
,7. A VA contractor is required to comply with the Service Contract Act (SCA) for a construction
project that includes janitorial services. Which of the following statements is correct?
A. SCA does not apply to construction contracts
B. SCA applies only if the janitorial services are performed by a subcontractor
C. SCA applies if the contract is principally for services, even if some construction is involved
D. SCA applies to all VA contracts regardless of the nature of work
Answer: A
Rationale: The Service Contract Act applies to service contracts, not construction contracts. Even if a
construction contract includes incidental services, the SCA does not apply. The Davis-Bacon Act
governs wage rates for construction. SCA applies only to contracts principally for services.
8. A VA contractor submits a claim for $500,000 under a contract that contains a 'Disputes' clause.
The contracting officer issues a final decision denying the claim in full. The contractor wishes to
appeal. Which of the following is the correct forum for appeal?
A. U.S. Court of Federal Claims
B. VA Board of Contract Appeals (VABCA)
C. Civilian Board of Contract Appeals (CBCA)
D. Either the CBCA or the U.S. Court of Federal Claims
Answer: D
Rationale: Under the Contract Disputes Act, after a CO's final decision, the contractor may appeal to the
agency board of contract appeals (for VA, the CBCA since 2007) or directly to the U.S. Court of Federal
Claims. The choice is the contractor's. The VABCA no longer exists.
9. A VA contractor is performing a design-build project. The contract requires the contractor to
obtain 'all necessary permits.' The contractor discovers that a local zoning permit is required but
the city denies it due to a conflict with the VA's design. Who bears the risk of the permit denial?
A. The VA, because it provided the design
B. The contractor, because it assumed the risk of obtaining permits
C. The risk is shared equally
D. The contractor, unless it can prove the VA's design was defective
Answer: B
Rationale: In a design-build contract, the contractor is responsible for both design and construction. The
requirement to obtain all permits places the risk of permit denial on the contractor, even if the design is
based on VA criteria. The contractor should have anticipated local requirements. The VA is not liable
unless it provided a defective specification in a design-bid-build context.
10. A VA contractor is awarded a contract that includes the 'Buy American Act' clause. The
contractor proposes to use foreign steel for a structural component because the domestic steel is
15% more expensive. Which of the following is correct?
A. The contractor may use foreign steel if the cost difference is less than 25%
B. The contractor may use foreign steel only if the CO grants a waiver
C. The contractor may use foreign steel if the domestic steel is not available in sufficient quantity
Page 3
, D. The contractor may not use foreign steel under any circumstances
Answer: B
Rationale: The Buy American Act requires use of domestic materials unless an exception applies. The CO
can grant a waiver if domestic cost is unreasonable (generally > 25% for construction) or if domestic
availability is insufficient. The contractor cannot unilaterally decide; a waiver must be obtained. The
15% difference here is below the typical threshold, but still requires a waiver.
11. A contractor is evaluating a project that requires a subcontractor to perform asbestos
abatement. The prime contractor's project manager has received a bid from a subcontractor that
is not listed in the VA's approved list for environmental remediation. The prime contractor is a
Class A VA contractor. Which of the following actions is most appropriate under VAAR 852.236-73
regarding the use of subcontractors for hazardous material abatement?
A. Proceed with the subcontractor after verifying their state license and insurance coverage.
B. Request a waiver from the VA contracting officer based on the subcontractor's equivalent qualifications.
C. Reject the bid and seek a subcontractor from the VA's approved list, as the clause mandates use of approved
sources.
D. Use the subcontractor but notify the VA within 5 business days of the subcontractor's identity and
qualifications.
Answer: C
Rationale: VAAR 852.236-73 requires that for hazardous material abatement, the contractor must use
subcontractors listed in the VA's approved list. The clause does not provide for waivers or equivalency.
Therefore, the bid must be rejected, and an approved subcontractor must be used.
12. A VA contracting officer is evaluating a bid from a Class B contractor for a project valued at
$750,000. The contractor's bid includes a 10% subcontracting plan for small businesses. The VA's
subcontracting goals for this project are 15% for small businesses. Which of the following is the
most appropriate action for the contracting officer?
A. Accept the bid because the contractor's plan meets the regulatory minimum of 10%.
B. Reject the bid as nonresponsive because the subcontracting plan does not meet the VA's stated goals.
C. Request a revised subcontracting plan from the contractor before award.
D. Award the contract but require the contractor to show good faith efforts to meet the 15% goal post-award.
Answer: B
Rationale: Under VAAR and FAR subcontracting regulations, the subcontracting plan must reflect the
contractor's commitment to achieve the goals set forth in the solicitation. If the plan does not meet the
stated goals, the bid is considered nonresponsive and must be rejected.
13. A Class A contractor is performing a renovation in a VA medical center. During the work, a
worker discovers a previously unknown underground storage tank (UST) containing hazardous
waste. The contractor immediately stops work and notifies the VA contracting officer. Under which
of the following clauses is the contractor entitled to an equitable adjustment for the resulting delay
and additional work?
A. FAR 52.236-2, Differing Site Conditions
B. FAR 52.236-3, Site Investigation and Conditions Affecting the Work
Page 4
EXAM AND VERIFIED ANSWERS
1. A VA contracting officer issues a unilateral modification to a fixed-price construction contract
citing the 'Changes' clause. The contractor believes the modification exceeds the scope of the
contract and files a claim. Under FAR Part 43, which of the following is the most critical factor in
determining whether the modification is within scope?
A. The dollar value of the modification relative to the original contract price
B. Whether the modified work is of a type not previously performed under the contract
C. Whether the contracting officer obtained prior approval from the head of the contracting activity
D. Whether the modification was issued before completion of the original contract
Answer: B
Rationale: Under FAR 43.201, a modification is within scope if it is within the general scope of the
original contract. The key test is whether the work is of a type not previously performed; if it is, it may be
a cardinal change. Dollar value alone is not determinative. Prior approval is not required for all
modifications, and timing is not dispositive.
2. A VA contractor incurs costs for lobbying activities aimed at influencing the award of a new
contract. Under the Cost Principles in FAR Part 31, which of the following is the correct treatment
of these costs?
A. They are allowable if the lobbying is directed at the VA only
B. They are unallowable regardless of the target of the lobbying
C. They are allowable if the contractor discloses them in the cost proposal
D. They are unallowable only if the lobbying is for a contract that would exceed the simplified acquisition
threshold
Answer: B
Rationale: FAR 31.205-22 explicitly states that costs of attempting to influence the award of a federal
contract are unallowable. This prohibition applies irrespective of the agency targeted or contract value.
Disclosure does not make them allowable. The rule is absolute to prevent misuse of public funds.
3. A Class A VA contractor is performing a $20 million renovation project at a VA medical center.
The contract requires a performance bond and a payment bond. The contractor obtains a bond
from a surety that is not listed on the Department of Treasury's Circular 570. Which of the
following is the most likely consequence?
A. The bond is valid but the VA may require additional security
B. The bond is invalid and the contractor must obtain a bond from a listed surety
C. The bond is valid if the surety is licensed in the state where the project is located
D. The bond is voidable at the VA's discretion
Answer: B
Page 1
,Rationale: Under the Miller Act and VAAR 828.102, bonds on federal construction contracts exceeding $150,000 must be
issued by sureties listed on Treasury Circular 570. A bond from an unlisted surety is invalid, and the contractor risks default
if not corrected. State licensing is irrelevant for federal contracts.
4. A VA contractor encounters differing site conditions during excavation for a hospital addition.
The contract contains the Differing Site Conditions clause. The contractor notifies the contracting
officer in writing within 10 days. The CO fails to respond. Which of the following statements best
describes the contractor's rights?
A. The contractor may proceed with a constructive change and later claim additional costs
B. The contractor must stop work until the CO responds
C. The contractor may proceed but waives any claim for additional costs
D. The contractor may terminate the contract for convenience
Answer: A
Rationale: Under FAR 52.236-2, if the CO fails to respond, the contractor may proceed with the changed
work and later seek an equitable adjustment under the Changes clause. Stopping work is not required
unless directed. Continuing does not waive the claim. Termination is not appropriate unless the changes
are fundamental.
5. Which of the following best describes the 'Competition in Contracting Act' (CICA) requirement
for full and open competition in VA contracts?
A. All contracts must be awarded to the lowest-priced, technically acceptable offeror
B. All responsible sources must be permitted to compete unless an exception applies
C. Only contractors with a Class A license may compete
D. Competition is required only for contracts exceeding $1 million
Answer: B
Rationale: CICA mandates full and open competition, meaning all responsible sources may compete.
Exceptions include sole-source, urgency, etc. Lowest-priced technically acceptable is one evaluation
method, not a requirement. Class A license is a VA-specific requirement, not a CICA mandate. The
threshold for competition is lower ($150,000 for construction).
6. A contractor is performing a cost-reimbursement contract for the VA. The contractor's
accounting system is deemed inadequate by the government. Which of the following is the most
immediate consequence?
A. The contractor may continue to bill costs but must improve the system within 30 days
B. The contractor may not be reimbursed for costs incurred after the determination
C. The contractor may be terminated for default
D. The contracting officer may withhold a portion of payments until the system is corrected
Answer: D
Rationale: Under FAR 16.301-3, if the accounting system is inadequate, the CO may withhold payments
up to 10% or more until the system is corrected. Reimbursement may continue subject to withholding.
Termination for default is not immediate; the contractor is given an opportunity to cure.
Page 2
,7. A VA contractor is required to comply with the Service Contract Act (SCA) for a construction
project that includes janitorial services. Which of the following statements is correct?
A. SCA does not apply to construction contracts
B. SCA applies only if the janitorial services are performed by a subcontractor
C. SCA applies if the contract is principally for services, even if some construction is involved
D. SCA applies to all VA contracts regardless of the nature of work
Answer: A
Rationale: The Service Contract Act applies to service contracts, not construction contracts. Even if a
construction contract includes incidental services, the SCA does not apply. The Davis-Bacon Act
governs wage rates for construction. SCA applies only to contracts principally for services.
8. A VA contractor submits a claim for $500,000 under a contract that contains a 'Disputes' clause.
The contracting officer issues a final decision denying the claim in full. The contractor wishes to
appeal. Which of the following is the correct forum for appeal?
A. U.S. Court of Federal Claims
B. VA Board of Contract Appeals (VABCA)
C. Civilian Board of Contract Appeals (CBCA)
D. Either the CBCA or the U.S. Court of Federal Claims
Answer: D
Rationale: Under the Contract Disputes Act, after a CO's final decision, the contractor may appeal to the
agency board of contract appeals (for VA, the CBCA since 2007) or directly to the U.S. Court of Federal
Claims. The choice is the contractor's. The VABCA no longer exists.
9. A VA contractor is performing a design-build project. The contract requires the contractor to
obtain 'all necessary permits.' The contractor discovers that a local zoning permit is required but
the city denies it due to a conflict with the VA's design. Who bears the risk of the permit denial?
A. The VA, because it provided the design
B. The contractor, because it assumed the risk of obtaining permits
C. The risk is shared equally
D. The contractor, unless it can prove the VA's design was defective
Answer: B
Rationale: In a design-build contract, the contractor is responsible for both design and construction. The
requirement to obtain all permits places the risk of permit denial on the contractor, even if the design is
based on VA criteria. The contractor should have anticipated local requirements. The VA is not liable
unless it provided a defective specification in a design-bid-build context.
10. A VA contractor is awarded a contract that includes the 'Buy American Act' clause. The
contractor proposes to use foreign steel for a structural component because the domestic steel is
15% more expensive. Which of the following is correct?
A. The contractor may use foreign steel if the cost difference is less than 25%
B. The contractor may use foreign steel only if the CO grants a waiver
C. The contractor may use foreign steel if the domestic steel is not available in sufficient quantity
Page 3
, D. The contractor may not use foreign steel under any circumstances
Answer: B
Rationale: The Buy American Act requires use of domestic materials unless an exception applies. The CO
can grant a waiver if domestic cost is unreasonable (generally > 25% for construction) or if domestic
availability is insufficient. The contractor cannot unilaterally decide; a waiver must be obtained. The
15% difference here is below the typical threshold, but still requires a waiver.
11. A contractor is evaluating a project that requires a subcontractor to perform asbestos
abatement. The prime contractor's project manager has received a bid from a subcontractor that
is not listed in the VA's approved list for environmental remediation. The prime contractor is a
Class A VA contractor. Which of the following actions is most appropriate under VAAR 852.236-73
regarding the use of subcontractors for hazardous material abatement?
A. Proceed with the subcontractor after verifying their state license and insurance coverage.
B. Request a waiver from the VA contracting officer based on the subcontractor's equivalent qualifications.
C. Reject the bid and seek a subcontractor from the VA's approved list, as the clause mandates use of approved
sources.
D. Use the subcontractor but notify the VA within 5 business days of the subcontractor's identity and
qualifications.
Answer: C
Rationale: VAAR 852.236-73 requires that for hazardous material abatement, the contractor must use
subcontractors listed in the VA's approved list. The clause does not provide for waivers or equivalency.
Therefore, the bid must be rejected, and an approved subcontractor must be used.
12. A VA contracting officer is evaluating a bid from a Class B contractor for a project valued at
$750,000. The contractor's bid includes a 10% subcontracting plan for small businesses. The VA's
subcontracting goals for this project are 15% for small businesses. Which of the following is the
most appropriate action for the contracting officer?
A. Accept the bid because the contractor's plan meets the regulatory minimum of 10%.
B. Reject the bid as nonresponsive because the subcontracting plan does not meet the VA's stated goals.
C. Request a revised subcontracting plan from the contractor before award.
D. Award the contract but require the contractor to show good faith efforts to meet the 15% goal post-award.
Answer: B
Rationale: Under VAAR and FAR subcontracting regulations, the subcontracting plan must reflect the
contractor's commitment to achieve the goals set forth in the solicitation. If the plan does not meet the
stated goals, the bid is considered nonresponsive and must be rejected.
13. A Class A contractor is performing a renovation in a VA medical center. During the work, a
worker discovers a previously unknown underground storage tank (UST) containing hazardous
waste. The contractor immediately stops work and notifies the VA contracting officer. Under which
of the following clauses is the contractor entitled to an equitable adjustment for the resulting delay
and additional work?
A. FAR 52.236-2, Differing Site Conditions
B. FAR 52.236-3, Site Investigation and Conditions Affecting the Work
Page 4
