OMB M-26-12 and the Federal Push Toward Commercial Buying
OMB M-26-12 directs federal agencies to increase acquisition of commercial products and services under Executive Order 14271. This post explains the memorandum’s reporting requirements, role of Senior Procurement Executives and competition advocates, and why contractors should prepare for greater scrutiny of non-commercial procurements.
Did Phase I of the Revolutionary FAR Overhaul Go Too Far?
Donald E. Mansfield analyzes whether Phase I of the Revolutionary FAR Overhaul complied with procurement notice-and-comment requirements. This post explains why immediate class deviations may create legal risk for federal contractors.
The Revolutionary FAR Overhaul and the Limits of Procurement Deregulation
A review of Phase I of the Revolutionary FAR Overhaul and why its use of immediate class deviations may matter for federal contractors, especially where fair opportunity and 8(a) follow-on requirements are affected.
Responding to a Cure Notice in Federal Contracting
A cure notice is a critical inflection point in federal contracting. This article explains how contractors should respond with speed, evidence, corrective action, and legal analysis to reduce the risk of termination for default and protect future contracting opportunities.
Firm-Fixed-Unit-Price Contracts and the FAR Overhaul: A New Acquisition Vehicle with Significant Practical Implications
The FAR Overhaul has surfaced a new contract vehicle: the firm-fixed-unit-price (FFUP) contract. This article explains what FFUP contracts are, how they differ from firm-fixed-price, T&M, and IDIQ arrangements, why they matter for cloud and metered services, and what federal contractors should watch for as agencies begin implementing them through agency procedures and solicitation language.
The FAR Overhaul, Schedule Buys, and the Quiet Contraction of Protest Opportunity
The FAR Overhaul (RFO) is reshaping bid protest dynamics by shifting Federal Supply Schedule ordering rules to GSAR/GSAM 538.71, expanding use of single-award BPAs, and accelerating post-award “brief explanations.” Fewer competitive decision points can mean fewer protests—not fewer errors, but fewer places to challenge them.
When the FAR Isn’t the Rulebook: A Quiet Reminder from the GAO OIG’s Latest Semiannual Report
A GAO OIG case closed on a simple premise—GAO is not subject to the FAR. This post explains why that matters for contractors, how “FAR-default” thinking creates proposal and compliance risk, and what to do instead when pursuing work with entities operating under different procurement authorities.
Cash Flow and the Reemergence of Prompt Payment Penalties
A prolonged shutdown has revived Prompt Payment Act interest penalties, exposing cash-flow vulnerabilities across the federal contractor base. This article analyzes why prompt payment rules, invoice “acceptance,” and rigorous documentation are now critical risk-management tools for vendors doing business with the U.S. government.
Big Contract Compliance Burdens Aren’t Just a Problem for Contractors
Federal News Network’s interview with Aron Beezley, hosted by Terry Gerton (with questions from Jared Serbu), explains how FAR-driven requirements now burden agencies and contractors alike—especially as universities move into traditional procurements. For vendors, “compliance by design” and standardized evidence reduce oversight friction, speed evaluations, and protect margins.
Part 52, Recast: Why the FAR Overhaul’s Clause Architecture Matters for Contractors
The FAR Overhaul rewires Part 52, reserving many legacy clauses and introducing the 52.240 series tied to new Part 40 security policies. Learn what moved, what’s new (e.g., 52.204-90/-91, 52.207-6), and why contractors must update clause matrices, proposals, and subcontracts now as agencies implement model deviation text across solicitations and awards.
“Time to Choose”: Why DoD’s New DFARS Conflict-of-Interest Rule Matters for Consulting Contractors
DoD’s new DFARS rule implementing NDAA §812 restricts awards under NAICS 5416 to consulting firms with foreign government ties unless they certify compliance or deliver an auditable mitigation plan. Effective Oct. 24, 2025, it extends to affiliates, raises protest risks, and demands robust global governance and information barriers.
Unified FAR Agenda Signals Tightening Cyber, Supply-Chain, and OCI Controls—What Contractors Should Expect in 2026
The Sept. 22, 2025 FAR Unified Agenda previews major compliance shifts for federal contractors in 2026: CUI harmonization, incident-reporting attestations, secure-software requirements, FASCSA exclusion orders, Section 889 enterprise-use bans, and revamped OCI rules. Here’s why these items matter and how to prepare.
Faster, Smarter Buying: New FAR “Companion”
The FAR Council’s 2025 “FAR Companion” accelerates commercial buying with RFQ-centric procedures up to $7.5M (and $15M for certain emergencies), emphasizes comparative evaluations on existing vehicles, and tightens debrief/protest timing.
The FAR Part 7 Line-Out: Why It Matters for Contractors
The FAR Overhaul’s line-out for Part 7 streamlines acquisition planning by reserving FAR 7.105 and shifting “how-to” detail to non-regulatory Practitioner materials, elevating agency procedures and class deviations. Contractors should monitor local policy, validate planning assumptions early, and track ongoing feedback windows to manage risk.
Interpreting the August 2025 FAR Overhaul: Implications for Federal Contractors
August 2025 FAR changes elevate best-in-class vehicles, embed shared-services preferences, streamline GSA Schedule ordering via GSAM 538, and expand simplified commercial acquisition (including $7.5M procedures). Contractors should prioritize BIC access, optimize catalogs for GSA’s emerging ecosystem, and recalibrate BPA and capture strategies to align with the new policy default.
Raising the Bar: FAR Council Finalizes 2025 Inflation Adjustments to Acquisition Thresholds
The FAR Council finalized FAC 2025-06, updating micro-purchase to $15k and simplified acquisition to $350k, raising key competition, reporting, and pricing thresholds, and adopting April 2025 CPI for accuracy. Most changes take effect October 1, 2025, preserving streamlined buying power against inflation.
FAR Overhaul UPDATE: A Look at Key Changes to Parts 11, 18, 39, and 43
The Trump Administration’s Executive Order 14275 has launched a major rewrite of the FAR. This post highlights GSA’s class deviations to FAR Parts 11, 18, 39, and 43 under the Revolutionary FAR Overhaul (RFO), streamlining procurement with plain language, flexibility, and modernized standards.
Why FAR Reform Alone might not Fix Federal Acquisition
Lt. Col. Matthew J. Fleharty argues in The Nash & Cibinic Report that FAR reform alone cannot fix federal acquisition. True progress demands investment in people, not just policy. His piece challenges conventional reform logic and calls for a revolution in workforce education.
FAR Rewrites and the Section 809 Vision
The May 2025 FAR lineouts show growing alignment with the Section 809 Panel’s vision for reform—highlighting mission-first acquisition, industry engagement, and streamlined oversight. This blog explores whether these changes mark a true transformation of federal procurement or just the beginning.
FAR 2.0: Ambition, Ambiguity, and the Need for Human-Centered Reform
President Trump’s FAR 2.0 rewrite aims to streamline procurement, but as Jennifer Ogren argues, success depends less on removing regulations and more on investing in people and judgment. This article explores the implications of the Executive Order and Revolutionary FAR Overhaul for government contractors.