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The FAR Isn't Procurement Policy (Weathering the RFO Series)
Over the past several months, one question has followed me almost everywhere I've gone.
"Shauna, what do you think about the Revolutionary FAR Overhaul?"
It's a fair question and my answer usually surprises people.
I don't answer it. At least not right away.
Instead, I usually ask a question of my own. "Which part?" Then I wait, maybe shuffle around, and take a deep breath.
The reason I ask – and display some body language that shows I’m anticipating the answer -- is because the Revolutionary FAR Overhaul isn't a single regulatory change. It's a fundamental reconsideration of how the Federal Acquisition Regulation should be organized, what belongs in it, and perhaps most importantly, what doesn't.
Depending on who you ask, it's “the most significant acquisition reform in decades”, a “risky departure from the procurement system we've relied on for more than forty years”, or a big “nothing-burger”. And I understand all of those perspectives.
But before I decide whether I agree or disagree with any particular change (proposed or in progress), I tend to go back to this one much simpler question.
What problem is the FAR Council trying to solve?
I've learned over the years that procurement regulations rarely appear or disappear by accident. Some exist because Congress required them. Some were added after GAO decisions exposed weaknesses in the acquisition process. Others grew out of Inspector General findings or years of agencies wrestling with the same recurring problems. Some were brought about to force consistent behavior and interpretation. And yes, some probably stayed in the FAR long after anyone could clearly explain why they were still there.
The challenge is knowing which is which.
That's why I decided to write Weathering the RFO. Not because I think I already know all the answers. But because I think we're asking the wrong questions.
Let's Start in a Different Place
One thing I've noticed as I've listened to conversations about the Revolutionary FAR Overhaul is that many of us instinctively started with the FAR itself. We started asking questions like:
"Why did they delete this section?"
"Why did they move this guidance?"
"Why are they shortening this part?"
Those are reasonable questions. I'm just not convinced they're the first questions we should ask. I think we should start somewhere else.
We should start with Congress. Here's why.
Congress, not the FAR Council, establishes federal procurement policy.
Congress decided that agencies should maximize practicable opportunities for small businesses.
Congress established full and open competition as the standard for federal contracting unless a statutory exception applies.
Congress created procurement integrity requirements, commercial acquisition authorities, and the socioeconomic programs that have shaped today's procurement landscape.
The FAR Council nor the FAR itself created those policies. FAR is how the rules Congress creates are implemented. That distinction may sound subtle, but I believe it's the key to understanding the Revolutionary FAR Overhaul. The RFO doesn't rewrite the Small Business Act, the Competition in Contracting Act, or the Office of Federal Procurement Policy Act. Those statutes remain exactly where they've always been. Instead, the FAR Council is asking a different question:
What's the best way to implement those laws through regulation?
Throughout the proposed rulemaking, the FAR Council explains that its objective is to retain statutory requirements and those necessary for sound procurement while removing or relocating other material that has accumulated in the FAR over time. That theme appears consistently throughout the initial set of proposed FAR cases and reflects the broader objective of simplifying the regulation without changing the underlying statutory framework.
Once I started looking at the RFO through that lens, the conversation changed for me. I stopped asking, "Why did they remove this?" And I started asking, "How will agencies accomplish the same objective now?"
To me, that's the more interesting and important question. Process edicts in the FAR have led behavior for decades. When process disappears, what leads behavior?
Why This Matters
One of the advantages of spending nearly four decades inside the Federal system and most all of that in the acquisition system is that you develop a healthy respect for unintended consequences. I've seen relatively small policy changes fundamentally reshape acquisition practices. I've also seen sweeping reforms generate months of debate before settling quietly into the background with very little long-term impact.
I’m taking a step back and now resisting the temptation to label the Revolutionary FAR Overhaul as either a success or a mistake before I talk and work through the changes with careful analysis and the experience of decades of best practices, lessons learned, “wish I could haves”, thought through it all with the patience it deserves.
Oh, there will almost certainly be changes that I think are overdue. There may be others that concern me. And there will probably be a lot that fall somewhere in between. That's because procurement has never been about absolutes.
It's about balance.
Competition and efficiency.
Flexibility and consistency.
Innovation and oversight.
Speed and stewardship.
Those competing priorities have always defined federal acquisition, and they don't disappear simply because the FAR suddenly becomes a shorter version of its former self.
The Conversation I Hope We Can Have
If you're looking for someone to tell you the Revolutionary FAR Overhaul is either the best thing that's happened to acquisition in decades or the worst, you probably won't find that here. That's not because I don't have opinions (because you know I do, if you’ve followed me for any length of time). Anyone who has spent a career in federal acquisition has opinions. It's because experience has taught me that good procurement decisions rarely begin with conclusions. They begin with understanding.
In each article in this series, I'm going to explore the questions I found myself asking as I read through the proposed rules.
What was Congress trying to accomplish?
How has the FAR historically implemented that objective?
What is the FAR Council proposing to change?
Why does the Council believe the change is appropriate?
And perhaps most importantly...What might this mean for the people who actually have to use these regulations?
· The Contracting Specialists and Contracting Officers.
· The Program and Project Managers.
· The Small Businesses Specialists.
· Small and large businesses.
· Agency and industry attorneys.
· Acquisition leaders at all levels in the organization, particularly those with front line responsibilities to guide the acquisition workforce daily.
Why?
Because procurement policy doesn't live in the Federal Register. It lives in acquisition offices across the Government, where real people make real decisions every minute of every day.
That's the ground zero where the Revolutionary FAR Overhaul w ill ultimately succeed or struggle.
From the Contracting Officer's Chair
One of the habits I developed over the years was resisting the urge to react and switch courses immediately upon policy changes before I understood the problem it was trying to solve. I always wanted to see how I could tie any changes into my business decision-making and critical thinking process I was already using as a Contracting Officer.
How did it make that analysis and decision process more solid but still ease my burden?
Sometimes a new requirement looked unnecessary until I learned it had been added after a series of successful GAO protests. Sometimes a procedure that seemed cumbersome turned out to be the Government's best evidence that a statutory obligation had been met. And often enough, a change in the regulation or a new regulation over time become little more than institutional inertia. Then there are the ones that just are what they are and you suck it up and keep plowing forward.
The point is I learned not to judge a requirement by its ageor by the number of pages it occupied in the FAR. I tried to first understandits purpose.
Looking at the big picture.
Looking at the small picture.
Looking at it from the lens of industry.
What could I learn from the change.
What did it do for the overall mission.
How did it support stewardship of taxpayer funds.
That's the mindset I'm bringing to this series.
My Perspective
As I finished reading the first group of proposed RFO rules, one thought stayed with me. I don't think the most important question is whether the FAR becomes shorter. I think the more important question is whether the acquisition workforce still has the tools it needs to faithfully carry out the procurement policies Congress established that form the foundation of the regulation itself.
Sometimes simplifying a regulation removes unnecessary burden. Sometimes it also removes a process that quietly helped agencies demonstrate compliance with the law. The challenge and the opportunity is knowing the difference.
That's the conversation I hope Weathering the RFO encourages. Not because I expect everyone to agree with my observations but because I think the acquisition community benefits when we take the time to understand not only what changed, but why it matters.
What is Coming Next -- Article Two: What Does "Nonstatutory" Really Mean?
One of the phrases that appears throughout the Revolutionary FAR Overhaul is nonstatutory requirements. Now at first glance, it seems self-explanatory, but I'm not sure it is.
In the next article, we'll unpack that phrase and explore why understanding it may be one of the keys to understanding the entire Revolutionary FAR Overhaul.
Watch for it here.
Author: Shauna Weatherly, President, Federal Subcontract Solutions LLC (dba FedSubK). Shauna is a small business advocate and owner of FedSubK. FedSubK exists to simplify federal contracting, empowering small businesses with practical, understandable resources. We bring first-hand experiences in Federal contracting from multiple perspectives derived from roles held both in and out of Government over almost four decades of Federal service.
Visit us at fedsubk.com to learn more about--
Getting Started in Federal Contracting: fedsubk.com/begin-your-journey-here
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The FAR Overhaul: Long-Deferred Maintenance on the Government's Procurement Highway
If you’ve ever worked in federal procurement — as a contracting professional, program manager, small business, prime, sub, or advisor — you’ve probably had this moment:
You’re doing your best to follow the rules…and suddenly you hit a clause, a cross-reference, or a requirement that feels like it came out of nowhere.
That’s because the Federal Acquisition Regulation (FAR) isn’t just a set of rules. It’s a highway system. A massive, heavily traveled road network that’s been patched, expanded, and rerouted for decades — and in many areas, it’s operating with years of deferred maintenance.
Let’s talk about what that really means using the highway analogy to explain why the Revolutionary FAR Overhaul isn't as "revolutionary" as some might think.
The FAR is like a Well-Traveled Federal Highway
The FAR is the main road that nearly every federal acquisition travels on. And like any highway system:
- Everyone uses it
- Everyone depends on it
- And over time, it’s been modified in ways that made sense in the moment… but created complexity later
If you look at any highway on Google Maps it shows a rather clean route. FAR, we were taught, was set up to be the same way: requirements, procedures, clauses, and guidance. But once you’re actually “driving” that road? Well, you realize the terrain is full of twists and turns. It's more complicated than you realized.
Hidden Guardrails: The Rules You Don’t See Until You Need Them
Some of the FAR’s most critical compliance safeguards are like guardrails buried under weeds or snow. They’re there for a reason: to prevent waste, protect fairness, ensure accountability. But they’re not always easy to spot. In practice, you often discover them when someone asks:
“Did you document that?”
“Where’s your justification?”
“Why didn’t you compete this?”
“Which clause applies here?”
That’s when you realize the guardrails were present the whole time — just not visible.
Guardrails are added all the time or in the process of being fixed (via rulemaking). But all that construction can clog up traffic and make the time for arrival (contract award) continually recalculate.
Hazards & Risks: Potholes, Speed Traps, and Fog
Now add in the hazards:
- Potholes = ambiguity and unclear language
- Fog = inconsistent interpretation across offices and agencies
- Construction zones = evolving policy updates, executive orders, and new mandates
- Speed traps = protests, audits, IG scrutiny, and compliance reviews
And these hazards hit different people differently. The same stretch of FAR may feel smooth to one team and treacherous to another. That’s not because the people are bad at driving — it’s because the road is uneven.
Side Roads & Gray Areas: The Detours Everyone Knows About
Then there are the side roads. Some are official alternate routes: simplified acquisition procedures, flexibilities, exceptions, and FAR “shortcuts” that exist for good reasons. Those are the routes people take because they’ve always taken them. Indicators might be hearing yourself or your peer say --
“We’ve always done it this way.”
“That’s how the last CO handled it.”
“This should be faster.”
“It’ll probably be fine.”
Side roads aren’t automatically wrong. But they come with risks, Eventually someone asks, “Why did you go that way instead of the main route?”
Others are the gray areas -- the gravel roads and roads only the locals (experienced COs/KOs) know. Those routes have to be navigated very carefully and even the best driver can have issues even if there is less traffic. Many times they beat those on the highway to their destination, but it's only because they know where all the seen and unseen hazards are from their years driving that route.
So What Is the FAR Overhaul, Really?
Here’s the key point:
✅ It is NOT building a new road.
✅ It is NOT bulldozing the FAR and replacing it.
✅ It IS road maintenance -- the kind that should've been done years ago.
And when you have decades of deferred maintenance, it takes a lot of work to make that road appear to be what it was all along.
But that's not "revolutionary". That's finally doing the work you've been putting off because you couldn't get to it.
The County (in this case, the FAR Council, being the governing body over the FAR and its contents) could always do a little better job at maintenance than they do. But their budget and resources are low and their workload demands are very high (just take a look at the FAR Open Case Report). Sometimes it takes a new Sheriff In town (a new Administration) driving down the highway see what those too close to it should have been aware of all along. Layers upon layers of deferred maintenance.
The FAR Overhaul is best understood as freshening up the same highway.
- Clearing overgrowth = outdated and redundant material and non-regulatory clutter.
- Improving signage = clarity and usability.
- Standardizing merges and exits = better consistency and flow.
- Removing obsolete detours = non-regulatory clutter, outdated terminology, and rules that no longer serve their purpose.
And a bonus is the updated maps available for your travels (FAR Companion and Practitioner Albums)
The destination isn’t changing. But the route is FAR more functional -- see how I did that. ;)
Why This Metaphor Matters
When people hear the word “overhaul,” they often assume “Everything is changing.” But what this effort really signals is “We are fixing the road we’ve been driving on for decades.” That’s important because procurement has become more complex, acquisition timelines are under pressure, and both agencies and industry need guidance that is easier to understand, apply, and defend.
If the FAR Overhaul is the same old FAR highway with better pavement, clearer signs, fewer surprises, and, hopefully, less time lost in detours, fewer compliance collisions, and a smoother drive for everyone. The biggest difference is that now all travelers know what the locals knew all along. How to get from point A to point B in less time using an updated road system and map.
Safe travels on the FAR Highway in 2026!
The FAR Is a Highway System… and the Revolutionary FAR Overhaul Is Long-Overdue Road Work
Contract Types and Contract Vehicles: The Difference Matters
Nuances matter in Federal Contracting. Those who haven't lived the Federal Contracting experience day in and day out may believe it's minor details that don't make a difference. They don't pick up on the nuances.
For those that have lived it from behind the walls of an agency know how those nuances can make a difference between how you are perceived building relationships with primes, potential team members and, most importantly, agency decision-makers.
One nuance -- Contract Types and Contract Vehicles.
Contract TYPES are defined by the pricing structure and risk ratio between the parties. They are:
✅️ Firm-Fixed-Price (FFP) to include FFP with Economic Price Adjustment (FFP w/EPA), Prospective Price Determination, Fixed-Ceiling Priced Contracts with Retroactive Price Redetermination, and those with a Level-of-Effort term (FFP-LOE).
✅️ Cost Reimbursement (or "Cost-Plus" ("CP")) to include cost sharing, Cost-Plus-Fixed-Fee (CPFF), Award Fee (CPAF), and Incentive Fee (CPIF).
✅️ Time-and-Materials (T&M) with materials on a fixed-price or cost-reimbursement basis.
✅️ Labor-Hour (L-H).
Contract VEHICLES provide the performance and administrative structure for the Contract Type. Those are:
✅️ Definitive Contracts are for specific stand-alone project(s) that fall above the Simplified Acquisition Threshold (SAT).
✅️ Indefinite Delivery Vehicles (IDVs) include Indefinite Delivery Indefinite Quantity contracts (IDIQs), Definitely Quantity, and Requirements vehicles. They include, but are NOT exclusively, governmentwide (GWACs), agency-specific, or GSA Multiple Award Schedules (MAS).
➡️➡️ Under the IDV umbrella falls task orders (services) & delivery orders (products) and specific instructions for who can order and how.
✅️ Agreements such as Basic Agreements, Basic Ordering Agreements (BOAs), and Blanket Purchase Agreements (BPAs).
➡️ ➡️ They are most often an umbrella for calls / orders (agencies call them both of these things even where FAR / RFO is specific, so it is easy to get confused), but don't have to be.
✅️ Purchase Orders (POs) (actions that fall under SAT).
✅️ Letter Contracts.
Yea, I know. FAR (even the RFO) lumps them all together as "Contract Types" in Part 16. But none stand alone. In my opinion, the FAR rewriters blew their chance to clarify this important piece of the procurement puzzle. For example:
▶️ IDIQs for services may include the ability to issue multiple types of task orders like fixed-priced, cost, T&M, and L-H under them, or only one type.
▶️ Definitive contract vehicles can be any contract type or combination thereof (hybrid) as indicated in the contract line items (CLINs) and for which terms and conditions are included.
Bottom line is -- There is not a complete understanding of a contract vehicle without defining its contract type(s).
If you see folks lumping TYPES and VEHICLES together in a discussion without explaining the difference, you know they aren't familiar with the nuances of this part of the FAR / RFO.
Follow those that are and have. Visit fedsubk.com and Expand your Federal Contracting knowledge today.
There are nuances in every FAR / RFO Part, including Part 16. We talk about why it is important to know and understand them in this marketplace.
FedSubK Feature: Be Seen! Why Your SBS Profile is So Important
UPDATED November 2025 to incorporate changes from the SBA Dynamic Small Business Search (DSBS) to the new SBA Small Business Search (SBS)
I’ve posted on LinkedIn a lot recently about ways to be seen as a little fish in the big pond that is the Federal marketplace. Every GovCon consultant has a take on the best entry points with agencies. My take is there is only one place small businesses MUST put their best foot forward to be quickly and easily seen by Federal buyers for potential opportunities and influence small business set-asides.
The Small Business Administration (SBA) Small Business Search (SBS) is THE PLACE you must be on your A-game.
The Small Business Search (SBS) is a database in which SBA houses information on the current pool of certificated small businesses. Presently, small businesses that do not have certifications or are self-certified, may also create a profile in this database. The SBS is used by contracting officers, small business specialists, large prime contractors, and other small businesses looking for teaming partners to find small businesses that can help meet Federal requirements and identify businesses that can help the Government (or a prime contractor) meet its small business goals. SBS is one of the first--and often only--sources used in market research by agencies to determine the numbers of small businesses able to provide products or services by North American Industry Classification System (NAICS) code.
You can see why this might be an important place to pay attention to, eh?
Businesses have forgotten about the SBS in the last few years because SAM.gov no longer sends small business registrants directly to SBS at the end of their registration to complete the profile like it used to. I HUGE bummer. Businesses now must wait for their SAM.gov registration to be activated, then they can establish an SBA SBS account, claim their entity record, and fill in their company profile in the SBS system. Federal buyers are looking for detailed information from SBS to use as part of their market research efforts.
SBS isn’t only for market research.
Even more importantly, the SBS shows Federal buyers the status of any pending certification applications for the purpose of determining whether you are eligible to compete for a set-aside action. For example, an Economically Disadvantaged Woman Owned Small Business (EDWOSB) can still submit an offer for an WOSB set-aside even with a pending application for certification showing in the SBS. Contracting Officers often use SBS as a source to confirm the socioeconomic certification status and 8(a) program participation along with SAM.gov.
While MySBA Certifications automatically sends socioeconomic certification status to SAM.gov and updates the requisite reps and certs to reflect the correct socioeconomic status, recently it has taken weeks for that migration to occur. WOSBs and EDWOSBs have reported not seeing their correct socioeconomic status reflected in their SAM entity record.
Businesses should always check their SAM entity record to ensure that the proper status is shown within a reasonable time after receipt of an active certification status; usually within 14 business days. If the record is not accurately reflected, you can contact answerdesk@sba.gov or the SBA socioeconomic program under which your business was certified for assistance. If a Contracting Officer says that your SAM record does not reflect the status claimed, ask the Contracting Officer to check SBS for the more accurate information because of these delays.
So now let’s talk about BEING SEEN in SBS and walk through each part of the registration.
Understanding how to maximize the fields in SBS is how you can make the best possible first impression so that Federal buyers want to learn more about YOU!
The Key Words
Often businesses pluck these from thin air and over-generalized based on what they think the Government wants to see. Key words need to reflect and incorporate aspects of your primary NAICS, secondary NAICS, and what you can provide under those NAICS. If you use key words that don’t reflect your primary NAICS, you’ll leave the Government scratching their head about you. They won’t understand the message you’re sending about your company. Be consistent and specific with key words while tying into your NAICS codes in order to leave the best impression. You have 500 characters -- use them wisely.
The Website
Be sure that you include the URL for any website you have. Make it be more than a landing page. It needs to tell your story. It needs to include information about your company, what you sell, past customers, and products or solutions you provide. And most of all, it must be polished. Scrub your site hard for formatting, typos, grammatical errors, etc. Acquisition personnel using the SBS will often quickly click on the site to see just how polished it is. When it looks good, they get the impression you know your stuff and pay attention to details.
The Capabilities Narrative
This is the written equivalent of your elevator pitch. This section should include all the things you’d include in that two-minute speech. Hit hard on what your company specialized in and its core product or service areas. Show the business’s focus and avoid being all over the map by overpromising on the breadth of work the business performs.
Near the end of the capabilities narrative, list any socioeconomic certifications Why not lead with it? Because that certification is only part of your business, and it alone does not get you interest from the Contracting Officer. End with that information so the Contracting Officer can easily see it in a quick query and get your business into their market research counts.
Lastly, identify any government contract vehicle or GSA Schedule your company may hold. If you can catch their eye that you have an existing GSA Schedule or your business participates in the 8(a) program, you’ll get counted and likely get a look in terms of the Contracting Officer wanting to know more. If they need to meet a socioeconomic goal, they can see quickly. You’re helping the Contracting Officer do their job. They LOVE that! (And made another great first impression!)
SBS now also includes a field to add a link to your online capabilities statement. Use it!
“Extras” You Should Never Skip
Performance History
I cannot say this enough…if you history doing work for any Government or quasi-Government entity at any level -- Federal, State, or Local level -- list them! Don’t play the “they’ll see that when I propose” game. Showing performance history—even if it is minimal or commercial and not Government--helps. How? It proves the viability of the business and the size and types of projects you’ve completed. Those goes a long way to determining eligibility of the business based on performance on same / similar work of a same / similar dollar value (“Rule of Two” stuff – you can read more about that here).
Review Your Profile
Go out to the SBS site and use the filters for your NAICS, business name, geographic location, and business types. Make sure your show up and see how your profile measures up to your competitors. Look at their records and see what they included that you haven’t. Use the good ideas of others, but don’t plagiarize. Contracting Officers will see that and that won’t look good for either of you.
Keep Evolving
Your SBS isn’t something that you can just set and forget either. Make reviewing your profile in SBS something you do when you renew your SAM.gov registration every year. If something major changes in your business focus, NAICS, or socioeconomic status, make associated changes in SBS.
What GovCon doesn't always talk about -- The SBS Influence
When doing market research and trying to determine if an acquisition should be set-aside for small businesses, the Government is not only counting about the numbers of small businesses that claim they can do the work under a NAICS code in SBS. They are analyzing your SBS profile to see if your business could be one of the "... two or more responsible small business concerns that are competitive in terms of fair market prices, quality, and delivery" and they have “…a reasonable expectation of obtaining an offer…” from you. (There’s that pesky “Rule of Two” again.)
In other words, based on what they see, could you submit a proposal likely to win? And how does a Contracting Officer determine that? Simply put... the your answers to everything we just covered.
Completing your profile helps tip the market research scales toward a small businesses set-aside and possibly a specific socioeconomic set-aside. If you're all over the map in your SBS narrative, the Government will not consider you viable eligible contractor towards that “Rule of Two” and could possible choose to go another way with their acquisition strategy, away from a small business set-aside. Or worse, they set it aside but remember your name from the market research as one of the businesses that didn’t make their initial market analysis cut.
Influence where you can! SBS is the place where you have a lot of influence!
Have I convinced you to get out there and create or update your SBS profile yet?
While the system is no longer got the word "Dynamic" in the title, don't forget its meaning. Life is dynamic, business is dynamic, and your SBS profile should still be dynamic, too. Get it completed ASAP. You can’t afford not to.
Remember again, SBS IS WHERE FEDERAL BUYERS GO TO FIND SMALL BUSINESSES and where other small businesses go to find teaming partners and subcontractors.
Get out there, GET NOTICED, BE SEEN, and STAY DYNAMIC!
(former title: FedSubK Feature: Be A Dynamic Small Business!)
Ask for the Meet and Greet & Make the Phone Calls
I sat in on a session yesterday where another GovCon was talking about watching SAM for opportunities. But if you are doing that, you are going to be too late, unfortunately. Small businesses must start ahead of any opportunity announcement and connect with agency personnel early, before the opportunity is announced in order to be known and help shape future acquisition strategies. It got me thinking about my days as a Branch Chief and Chief of Contracting and the small businesses I know that are still flourishing today.
One particular company stands out. They were a new 8(a) firm that asked for a meet and greet. They had no federal work but showed a level of understanding about our mission that made an impression. While our acquisition strategies were in place already for the end of FY run of award, I told them I'd keep them in mind new projects crossed my desk.
Every month, without fail, I would get a call or a quick drop in chat from this 8(a) to say hello and briefly inquiry about any possible upcoming projects. During one of the in-person chats about a year after our first meeting, our chief estimator popped his head in my office quickly to apologize for a few late government estimates. He said he was going crazy with end of FY and lack of staff. The 8(a) took the opportunity and said, "We can help with that." While it wasn't ideally the work the 8(a) was looking for, that simple pivot and flexibility, along with the relationship building done to that point, led to a small 8(a) sole source contract for cost estimating support. It was their first federal contract.
That small contract quickly turned into a much larger 8(a) sole source contract for the same work that reached its max capacity 18 months earlier than anticipated. That led to 8(a) contracts for environmental the work the company ideally wanted, then graduation from the 8(a) program, and successfully competing on SB set-asides throughout the region and getting their own (successful) GSA Multiple Award Schedule contract.
Ask for the meet and greet. Make the phone calls. This former Contracting Officer is here to tell you that acquisition personnel and Small Business Specialists EXPECT to hear from businesses. Large businesses aren't shy about calling -- trust me.
Federal employees may not be able to tell you much depending on the stage an acquisition is in, but the relationship building and continual reminder that you know what they are looking for and can fill a niche -- even when it's not your first choice of work -- is KEY.
Small businesses must start ahead of any opportunity announcement and connect with agency personnel early, before the opportunity is announced in order to be known and help shape future acquisition strategies. (Updated: December 2025)
FedSubK Feature: What is Buying In?
"Buying in". Do you know what that is? Let's illustrate it with a little story...
Once upon a time an agency leader🤴 was looking around at things to make 🌟efficient.🌟 They got the idea that every agency should have the same widgets🔅 their agency had.
The agency leader🤴 called up a widget company👩🔧 and said, "We are interested in your widgets. 🔅What kind of discount can you give us?"
The widget company👩🔧 offers a discount 📉 because they know this agency🤴 not only buys for themselves but may buy for other agencies🫅🤴👸 where a highly trusted widget competitor👨🔧 presently has the work.
The widget company👩🔧 was "buying in" -- offering unrealistic discounts📉 that made the price unrealistically low not only for the current effort but also to influence the purchasing decisions on future buys. Then prices usually up 📈 again over time.
Depending on when "buying in" happens there could also be questions related to compliance with the Competition in Contracting Act (CICA) and possible other violations.
This is why agency announcements that management has made a deal for "$1 a license" and other such management interference is of concern. 🚨 Management plays the numbers game. I'm not saying numbers aren't important, but let's just say... there is a real reason why management typically does not hold contract signature authority. 😬😉
The Government is supposed to keep things fair and do its due diligence. But it's falling for the oldest trick in the book.
Risk, intent, compliance with statutory requirements, misunderstanding of requirements, and comparable market pricing must be evaluated when the Contracting Officer has reason to believe a proposed price is unrealistically low price. But are they?
If a contract isn't in place, there there is still a need to follow appropriate competition rules before a handshake deal. If a contract is already in place, there are things to consider when new discounts appear to be unrealistic including the risk of continued performance, depending on the type of product or service being purchased.
The Government gets a quick win to lock in a low rate, saving some money now. That's called the short game. Government buyers getting blurry-eyed over unbelieveably low prices and don't do the long-term analysis.
But I'll bet you a dollar the company is playing the long game. They are watching and waiting, getting to know your needs and asking loads of questions. "When do you use my widget most?" "Who buys the most widgets?" "When do you typically buy widgets?" And then as fast as they dropped the price, they raise it again on you when you can't afford to make a change -- like at an end of fiscal year. That's how they get locked in and receive perpetual contracts.
BTW...the fairy tale above is a true story. I've had new politicals and new leadership / commanders trot companies into my office saying "Company ABC here says they want to sell us "widgets" at a huge discount compared to what we're paying or others are paying now."
Well...okay then.
As a Contracting Officer, whether I could even begin to entertain that idea depends on several things. It's not an automatic "yes". You could replace "widgets" with just about any product or service and it's probably happened to a Contracting Officer somewhere. Especially as new Administrations come into Government.
The stories in the news that made me think -- "Huh, are they buying in?" are the Axios story "Anthropic wants to sell Claude to the Government for $1". (https://www.axios.com/pro/tech-policy/2025/08/05/ai-anthropic-government-sale-dollar) and FedScoop story "Federal agencies can buy ChatGPT for $1 through GSA deal" (https://fedscoop.com/openai-chatgpt-enterprise-federal-government-gsa-deal-general-services-administration-anthropic/).
My husband (also a retired Contracting Officer) and I look at each other often during the news now and, based on the reported discount or price alone, we know that company is likely "buying in". That's based on our combined 72 years of Fed experience and our Contracting Officer "Spidey sense" from having been around the block a few times. But these deals just the most recent in a series of deals GSA is making with companies since the new Administration came to town. OneGov is the program GSA is, in my former Contracting Officer opinion, using to tout savings under for the press releases. But it may come back later to be a big mistake. I hope I'm wrong.
Program/Project Managers and Contracting Officers AND the competition to these companies...LEARN about it and WATCH for it. It's on the rise.
(And don't get me started on having to argue with new politicals, leadership, and commanders about why I can't terminate a current contract and then turn around and give the same work to another contractor at their unrealistic lower price.🙄😱 That's a topic for another time.)
The practice of "buying in" is becoming more common now. Learn about it and how to spot it.
