Qualifications-Based Selection for Architects and Engineers: How QBS Scoring Works

When the board asks why the fee was not on the scoresheet

A facilities manager at a grant-funded nonprofit has just finished interviewing three engineering firms for a building renovation. The committee agrees on a clear first choice. Then a board member asks why price appears nowhere on the scoresheet. Separately, one of the unsuccessful firms asks for a debrief and wants to know how its qualifications were rated.

Both questions are fair, and both have answers that sit in the file or do not. If the criteria, ratings and rationale were written down in order, the manager can show how the ranking was reached. If they were reconstructed from memory and email, the same questions get harder with each week that passes.

Qualifications-based selection, usually shortened to QBS, is a deliberate exception to how most competitive proposals are scored. This article explains how that exception works under federal grant rules, how to build a scoring sheet for it, and what the file should show when fee negotiation begins. After reading, you should be able to explain where price sits in a QBS process and record each step in the sequence that actually happened.

What 2 CFR 200.320(b)(2)(iv) allows, and where the Brooks Act fits

Under a federal award, 2 CFR 200.320 sets out the formal procurement methods. For the proposals method, an entity evaluates offers against stated factors, and under 2 CFR 200.320(b)(2)(iii) contracts "must be awarded to the responsible offeror whose proposal is most advantageous to the recipient or subrecipient considering price and other factors." Price normally counts.

QBS is the carve-out. Under 2 CFR 200.320(b)(2)(iv), qualifications-based selection evaluates qualifications, selects the most qualified offeror, and then negotiates fair and reasonable compensation. The regulation says this method, where price is not a selection factor, "can only be used to procure architectural/engineering (A/E) professional services." Confirm the exact paragraph numbering on eCFR, which describes itself as authoritative but unofficial. The official edition is the annual CFR on govinfo.gov.

The federal model for this is the Brooks Act (40 U.S.C. 1101–1104), which governs how federal agencies themselves select A/E firms. A grant recipient does not apply the Brooks Act directly; it follows 2 CFR 200.320(b)(2)(iv). The Act's policy, in 40 U.S.C. 1101, is to announce A/E requirements publicly and to negotiate contracts:

"on the basis of demonstrated competence and qualification for the type of professional services required and at fair and reasonable prices."

Many states have their own QBS statutes, often called "mini-Brooks" laws. They vary, and this article does not summarize any of them. If a state or local rule is stricter than the federal one, follow the stricter rule. Check your state's law, and ask your awarding agency or pass-through entity how it applies to your award.

For the wider picture of how 200.320 organizes informal, formal and noncompetitive methods, see this overview of 2 CFR 200.320 procurement methods.

Qualifications based selection architect engineer: where price sits in the process

Price is excluded as a selection factor. It is not excluded from the procurement. The process moves in a sequence, and the file should show that sequence.

Step 1: Define the scope and the criteria

The solicitation describes the project and identifies every evaluation factor with its relative importance. That duty comes from 2 CFR 200.320(b)(2)(i), which applies to proposals generally. In QBS, none of the factors is a fee.

Step 2: Score qualifications only

Evaluators rate each firm's submittal against the stated factors. Fee proposals are not requested at this stage, so they cannot influence the ratings.

Step 3: Rank the firms

The committee ranks firms by total qualifications score, usually after consensus on any items where evaluators disagreed. Many offices also shortlist firms for interviews before the final ranking. The solicitation and local policy set how.

Step 4: Prepare the independent estimate

Where a cost or price analysis applies, 2 CFR 200.324(a) requires one for every procurement transaction above the simplified acquisition threshold, and independent estimates must be made before receiving bids or proposals. Confirm the current threshold with your awarding agency. Your professional-services scope should have its own estimate on file before any fee discussion begins. The regulation does not define "independent," but in practice the estimate need not come from a third party; it should be built without input from anyone with a financial stake in the award. Our guide to the independent cost estimate under 2 CFR 200.324 covers this in more detail.

Step 5: Negotiate with the top-ranked firm

Only now does compensation come up. The issuer negotiates a fair and reasonable fee with the most qualified firm and compares the result with its estimate. Record the outcome, whatever it is.

Building a QBS scoring sheet

A QBS scoring sheet is an ordinary weighted-criteria sheet with the price category removed. The weights still total 100, and every rating point still needs a written definition before any evaluator scores anything. If you want a fuller treatment of those mechanics, see how to write RFP evaluation criteria.

Typical A/E factors include:

• relevant project experience;
• qualifications of key personnel;
• technical approach to the project;
• past performance on similar work;
• capacity to deliver within the project schedule.

These are illustrations. Your solicitation sets the actual list and the weights.

Geographic location needs care. The version of 2 CFR 200.319 in force before October 1, 2024 barred geographic preferences in most cases and allowed location as an A/E criterion only where enough qualified firms remained to compete. The current text has no geographic-preference provision, but 200.319(a) still requires full and open competition, and program rules, award terms or state law may restrict local preferences. If you use location as a factor, check those first and record why you concluded it was permitted and left enough firms to compete.

Conflict-of-interest rules apply to the committee as well. Under 2 CFR 200.318(c), no employee, officer, agent or board member with a real or apparent conflict of interest may take part in the selection, award or administration of a contract supported by the federal award. Collect a written attestation from each evaluator before scoring starts.

Worked example: a weighted QBS score

This is a worked example with round inputs, not a model for your weights. Suppose weights of 30, 25, 20, 15 and 10, and ratings on a 0–5 scale, where each score is the rating divided by 5 and multiplied by the weight.

Factor (weight)	Firm A rating	Firm B rating	Firm C rating
Project experience (30)	5 → 30	4 → 24	3 → 18
Key personnel (25)	4 → 20	5 → 25	3 → 15
Technical approach (20)	4 → 16	3 → 12	4 → 16
Past performance (15)	4 → 12	5 → 15	3 → 9
Capacity (10)	3 → 6	4 → 8	5 → 10
Total (100)	84	84	68

Firms A and B tie at 84. A tie rule chosen before scoring settles it, for example by a higher score on the heaviest-weighted factor. A rule invented after the totals are visible invites exactly the challenge you want to avoid. Firm C ranks third, and the file should show the ratings behind that result.

Ranking firms and negotiating fees in rank order

Rank order carries real consequences in QBS. The firm ranked first is the one the issuer approaches about compensation. In common practice, if the parties cannot agree on a fair and reasonable fee, the issuer ends that negotiation and approaches the next-ranked firm. The solicitation and your local policy control the details, so confirm yours before you rely on this sequence.

Three records matter here:

• the ranking itself, with the date it was finalized;
• the independent estimate, dated before negotiation began;
• the negotiation outcome for each firm approached, including the fee basis and the reason for any breakdown.

The last record connects to 2 CFR 200.318(i), which requires records detailed enough to show the history of each procurement. They must include the rationale for the method, the contract type selection, contractor selection or rejection, and the basis for the contract price. In QBS, the basis for price is the negotiated fee measured against the estimate, so that comparison belongs in the file.

If a firm challenges the outcome, 2 CFR 200.318(k) makes the recipient or subrecipient responsible for settling the contractual and administrative issues arising out of its procurements. "These issues include, but are not limited to, source evaluation, protests, disputes, and claims." Your own record is the main support for the response. The federal text does not set a protest procedure; that comes from your own policy and state or local law, so check yours.

Request for qualifications versus request for proposals

Offices often ask whether a request for qualifications and a request for proposals are really different documents. The difference lies in what the document asks for, not in its title.

A request for proposals under the standard proposals method asks for a technical response and generally a price, and price is a scored factor. A request for qualifications, as many offices use the term for A/E work, asks for firm and team qualifications and does not ask for a fee. Naming practice varies by office and by state. Some A/E solicitations carry the "RFP" label but ask only for qualifications, and some use "RFQ" for other purposes entirely.

Whatever the label, the file should show which method you used and why. If you are weighing formal methods more broadly, this comparison of RFPs and invitations for bids explains how sealed bids differ. Under 2 CFR 200.320(b)(1), a sealed-bid contract goes to the responsible bidder whose conforming bid is lowest in price, which is the opposite logic from QBS.

What to record in the file, and where to go next

A QBS file that supports a later review is not complicated. Check that it holds:

• the solicitation, with the criteria and weights it announced;
• the written definition of each rating point, dated before scoring;
• each evaluator's conflict-of-interest attestation;
• independent score sheets and the consensus rationale for any changed score;
• the final ranking and the tie rule that applied;
• the independent estimate, dated before negotiation;
• the negotiation record and the fee basis.

Under 2 CFR 200.334, records are generally kept for three years from the date the final financial report is submitted, unless an exception applies, and local public-records rules may require longer. Confirm the period with your awarding agency.

RFPManagement is being built to hold this kind of record: weights that must total 100, rating anchors fixed before a round opens, scoresheets hidden until the round is locked, and a consensus record that requires a rationale for each final score. Scoring stays with your evaluators, because the product is designed with no AI scoring. One related store workbook, the Qualifications-Based Selection (A/E) Scoring Workbook, is designed to rank A/E firms on qualifications only, with no price columns, and to log fee negotiations in rank order. It is available in the store now. To hear when the evaluation workspace and the store open, join the waitlist.

RFPManagement records and computes. It does not give legal or procurement advice. The award decision stays with your organization.