FedSubK Feature: Hate the Game, Not the Players - Know the Roles in Federal Contracting
Updated: May 4, 2024
The Federal procurement process has a lot of pain points and it can be a love-hate relationship doing business in the Federal marketplace. But knowing who is involved in the process from the Government can go a long way in navigating frustration and finding avenues to build relationships that, over time, may provide business opportunities. Each role we’ll discuss sees the acquisition with a unique perspective and often a specific filter. But they all have the same end goal; meeting the agency's mission. Understanding who is involved and they perspective they bring is key to talking about the right things with the right people at the right time.
Let's take a closer look at the main roles involved for the Government.
Requiring Activity
The Requiring Activity is the agency or activity charged with meeting a mission and delivering requirements to the end-user, whether an internal or external Government customer. It is responsible for obtaining funding or developing the program objective memorandum. It may also be the organizational unit that develops the written requirement or Statement of Work (or other format) for services requiring a contract. The Requiring Activity can also be the Funding Activity and/or Procurement Activity when it receives appropriated funds directly for the requirement and/or it has the requisite procurement authority and contracting expertise for the type of contract required. Finally, the Requiring Activity supplies a trained and qualified Contracting Officer's Representative (COR) capable of deciding whether service contract requirements are being performed per the contract.
Funding Activity
This is the agency or activity that receives the funding appropriation that will be used to pay for the products or services being procured. The Funding Activity may be part of the Requiring Activity or Procuring Activity, such as the budget or finance office of an agency/organization.
Procuring Activity (also called Contracting Activity)
This is the agency or activity with expertise and procurement authority that will manage the acquisition of the products and/or services required. The Procuring Activity initiates the Federal contracting process by establishing the acquisition strategy, often in consultation with the Requiring Activity (if it is a separate entity). It develops solicitations, responds to industry questions, and oversees the offer, evaluation, negotiation, and contract award activities. The Procuring Activity may also be the entity that oversees contractor performance through contract closeout. However, contract administration activities may be handed to another activity, like the Defense Contract Management Agency (DCMA), when it is part of the agency’s/organization’s process to do so or required by agency policy.
Senior Procurement Executive
The Senior Procurement Executive (SPE) is the individual appointed per 41 U.S.C. 1702(c) who oversees the management direction of the acquisition system of the executive agency, including implementation of the unique acquisition policies, regulations, and standards of the agency. The SPE initiates acquisition policy rulemaking for the agency and decides the processes and procedures to be used in acquisition planning, contract formation, negotiation, contract administration, and contract closeout. The SPE is typically a member of the Senior Executive Service (SES) and a career Federal civilian.
Head of the Contracting Activity
The Head of the Contracting Activity (HCA) is the official who has overall responsibility for managing the Procuring or Contracting Activity. The SPE may choose to delegate certain responsibilities to the HCA for day-to-day management of acquisition processes and certain approvals, when allowable. The HCA may waive certain contractual requirements under specific circumstances allowed by regulation. These authorities are not usually eligible for further delegation to a lower level.
Contracting Officer
The Contracting Officer (CO) is the person with the authority to enter into (sign), administer, and/or terminate contracts and make related determinations and findings. The term includes certain authorized representatives of the contracting officer acting within the limits of their authority as delegated by the contracting officer such as–
- Administrative contracting officer (ACO) – refers to a contracting officer who administers contracts during performance.
- Termination contracting officer (TCO) – refers to a contracting officer who is settling terminated contracts.
A single contracting officer may handle duties in any or all areas of contract formation, performance, termination, or closeout.
The Department of Defense uses “KO” in short for “Contracting Officer” so as not to confuse contracting officers with the military term Commanding Officer (CO).
Contrary to popular belief, the CO does not work in a vacuum and rarely makes all decisions alone. When I was a CO, we would talk with other COs, our supervisory COs, our Contract Specialists, and the entire team listed in this article to make well-rounded business decisions with buy-in. We called it "Contracting by Committee" because we knew that while we knew the regulations, didn't have all the answers and needed all perspectives.
Contract Specialist
The Contract Specialist (CS) is the person who assists the CO/KO in all aspects of the contracting process by preparation of documents, communications with industry, negotiation of contract prices, selection of terms and conditions, coordination and routing of contract documents, oversight of contractor performance, and contract closeout. The CS cannot enter into (sign) contractual instruments nor verbally obligate the Government. The CS may not make decisions on any contract action (pre or post award) that changes the scope, schedule, price, or terms and conditions. They are often the face to the public on solicitations, communications, and other activities that do not require CO/KO input or approvals.
Contracting Officer’s Representative
The Contracting Officer’s Representative (COR) is an individual designated and authorized in writing by the CO/KO to perform specific technical or administrative functions before and during contract performance. The COR oversees the daily activities of contract performance as the eyes and ears for the CO/KO. The COR cannot enter into (sign) contractual instruments nor verbally obligate the Government. The COR may not make decisions or make commitments that change the scope, schedule, price, or terms and conditions of any contract action. The COR does supply input on the contractor’s performance for use by the CO/KO in required performance evaluations.
Very often the COR is from the Requiring Activity and is a technical subject matter expert or program/project manager responsible for the delivery of products or services to the end user. The COR has likely been involved in the acquisition since its inception and has provided counsel and technical guidance to the CO/KO and possibly participated in the development of evaluation factors and criteria, and source selection activities.
Small Business Specialist
The Small Business Specialist serves as an advisor to the CO/KO and Requiring Activity in the development of the acquisition strategy by encouraging opportunities be available for participation by small business concerns within the various socioeconomic programs. They serve small businesses by providing information on how to do business with the Federal Government and maintain a small business outreach program for the Procuring or Requiring Activity. The Small Business Specialist is responsible for monitoring and maintaining statistical data related to the acquisition process. They also assist small businesses that have issues obtaining payments or are receiving late payments as a prime or sub.
Procurement Center Representative (PCR)
Procurement Center Representatives (PCRs) are employed by the Small Business Administration (SBA) and advocate on behalf of the SBA and small businesses in the acquisition process. PCRs work closely with agency contracting staff on upcoming requirements, review acquisition strategies and solicitations, and inform agencies as to updates to SBA regulations and changes in SBA certification programs. PCRs are also a resource to assist agencies in meeting their small business goals and review subcontracting plans from large businesses for compliance before award. PCRs receive copies of cure or show cause notices of small businesses in their territory that are struggling to meet performance requirements.
Supporting Personnel
Others in the Government team may also be involved in the procurement process such as legal counsel, technical experts, budget analysts, and Government Contractor support personnel. These folks play a necessary supporting role to our key players. They are often the other bodies in the room who may not speak, but hear everything you say, also with their unique perspective. They provide subject matter advice to the procurement official. They are the folks you shake hands with at industry conferences and expos. Making an impression and having a well-honed elevator pitch (2 minutes tops) about your company’s capabilities is important to use when communicating with these roles. They can be the people that remind one of the key players about your company.
Federal Contracting is a team sport. The interplay between government personnel in the roles that play a key part in acquisition and industry is crucial for problem-solving and driving innovation in the government space. As you can see, understanding the roles of key players in government is important in developing productive relationships and talking to the right people about the right things. Finding shared goals through mutual perspectives and appreciating each of these roles in Federal contracting from that view allows you to meet each player in the process where they are, know what they do, and lead them to you as a trusted resource and solution-maker.
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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
Solutions and Our Trusted Support Provider Network: fedsubk.com/solutions-services
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Free Webinars and Resources: fedsubk.com/webinars-training
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.
