FAR & Beyond: Time for A Revolutionary MAS Overhaul!
This week saw the start the formal rule-making phase of the Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO). On Tuesday, the FAR Council published 17 sections of the FAR for public comment. This marks the beginning of a transformative period where the RFO deviations become formal, final rules. It is a welcome next step with an ambitious goal of finalizing the FAR by the end of the calendar year.
As progress streamlining the FAR continues, there are related opportunities for revolutionary procurement reform. Given the Administration’s focus on simplifying and streamlining procurement, and its emphasis on commercial buying, the General Services Administration (GSA) should embark on a Revolutionary Multiple Award Schedule (MAS) Overhaul (RMO). The MAS program is the government’s largest commercial item contract vehicle. As such, it should lead by example, reducing unnecessary, burdensome provisions, procedures, and policies that increase costs and create barriers to entry for commercial vendors.
As a first step, GSA should review the MAS solicitation and attachments consistent with the RFO’s policy goals of streamlining procurement and buying commercial. The MAS solicitation with attachments is approximately 600 pages. The sheer number of pages indicates a complex set of requirements and a voluminous set of instructions, clauses, and data requests from potential offerors. GSA has made foundational progress in consolidating the MAS solicitation, eliminating the Commercial Sales Practices requirements, eliminating the Price Reduction Clause, and adopting Transactional Data Reporting. These foundational changes, buttressed by the RFO, create a genuine opportunity for a top-down review of the MAS solicitation, procedures, system, standards, and processes.
Moreover, the reorganization of the Federal Acquisition Service (FAS) provides a management framework for the RMO. The new Office of Acquisition Solutions Development (Create) manages the entire MAS program, allowing for greater consistency and efficiency in operations. The reorganization also brings GSA’s Office of Acquisition Policy front and center as the lead on all MAS policy. These two offices, with input from internal and external stakeholders, can launch the RMO to reduce administrative burdens, increase access to the commercial market, reduce costs, standardize and drive best value for customer agencies.
Look for future blogs on RMO opportunities. The impact can be revolutionary.
FAR Council Publishes First RFO Proposed Rules
The Federal Acquisition Regulatory (FAR) Council has published four proposed rules that would update the FAR by codifying The Federal Acquisition Regulatory (FAR) Council has published four proposed rules that would update the FAR by codifying changes made under the Revolutionary FAR Overhaul (RFO). This first set of proposed rules covers 17 FAR parts.
- FAR Case 2026-002 proposes changes to FAR-
- Part 6 (Competition Requirements)
- Part 7 (Acquisition Planning)
- Part 10 (Market Research)
- Part 18 (Emergency Acquisitions)
- Part 26 (Other Socioeconomic Programs)
- Part 37 (Service Contracting)
- Part 41 (Acquisition of Utility Services) and
- Part 52 (Solicitation Provisions and Contract Clauses)
- FAR Case 2026-007 proposes changes to FAR-
- Part 3 (Improper Business Practices and Personal Conflicts of Interest)
- Part 49 (Termination of Contracts)
- FAR Case 2026-005 proposes changes to FAR-
- Part 5 (Publicizing Contract Actions)
- Part 24 (Protection of Privacy and Freedom of Information)
- Part 29 (Taxes)
- Part 52 (Solicitation Provisions and Contract Clauses)
- FAR Case 2026-001 proposes changes to FAR-
- Part 1 (Federal Acquisition Regulations System)
- Part 2 (Definitions of Words and Terms)
- Part 4 (Administrative and Information Matters)
- Part 33 (Protests, Disputes, and Appeals)
- Part 39 (Acquisition of Information and Communication Technology)
- Part 40 (Information Security and Supply Chain Security)
- Part 52 (Solicitation Provisions and Contract Clauses)
- Part 53 (Forms)
The FAR Council has also published a “You Said, We Did” webpage summarizing feedback received during Phase 1 of the RFO with explanations about how that feedback informed the proposed rules.
Comments on the proposed rules are due to the government by July 23.
If you have comments on one or more of these proposed rules, please email them to Greg Waldron at gwaldron@thecgp.org by 5:00 PM ET on July 7.
NASA Announces SEWP VI Awards
The National Aeronautics and Space Administration (NASA) has announced more than 2,000 awards under its Solutions for Enterprise-Wide Procurement (SEWP) VI governmentwide acquisition contract.
The awards span three categories:
- Category A – IT Solutions: 364 awardees
- Category B – Enterprise-Wide IT Service Solutions: 692 awardees
- Category C – IT Mission-Based Services: 1,059 awardees
SEWP VI will provide agencies with access to a broad range of IT products, services, and solutions through a 10-year ordering period running from November 1, 2026 through October 31, 2036. Each contract carries a maximum value of $20 billion.
GSA Issues Made in America RFI
The General Services Administration (GSA) has issued a Request for Information (RFI) seeking feedback from industry stakeholders on ways to make it easier to identify and purchase American-made products through GSA Advantage.
According to GSA, the RFI supports implementation of Executive Order 14392, “Ensuring Truthful Advertising of Products Claiming to be Made in America.”
Industry stakeholders interested in providing feedback may submit responses through GSA’s online RFI portal here. Responses to GSA are due on July 24.
The Coalition is collecting member feedback in response to the RFI. To contribute to the Coalition’s submission, please send your comments to gwaldron@thecgp.org by July 15.
SBA Releases FY25 Federal Procurement Scorecard
The Small Business Administration (SBA) has released its fiscal year (FY) 2025 federal procurement scorecard, reporting that the Federal Government exceeded its statutory goal of awarding 23 percent of prime contract dollars to small businesses. According to SBA, nearly 28 percent of prime federal contract dollars, representing approximately $179 billion, were awarded to small businesses during FY25. Including both prime contracts and subcontracts, federal agencies awarded nearly $273 billion to small businesses.
SBA reported that small business prime contracts supported an estimated 793,400 jobs, while small business subcontracts supported an additional 418,000 jobs across industries including manufacturing, construction, research and development, technology, and defense.
The scorecard also highlights changes affecting the 8(a) Business Development Program. According to SBA, 8(a) firms received $24.3 billion in prime contract awards, or 3.7 percent of all prime contract dollars, a decrease of $1.5 billion from FY24. SBA also noted that it has initiated an audit of the 8(a) Program, proposed revisions to its admissions framework, and taken actions to remove firms that failed to meet program requirements.
In addition, SBA reported that Service-Disabled Veteran-Owned Small Businesses (SDVOSBs) received $32.5 billion in prime contract awards, exceeding the government’s five percent statutory goal.
Overall, the Federal Government received an A grade on the FY25 scorecard. GSA, the Department of Housing and Urban Development, and the Department of Commerce each received A+ grades.
GSA to Transition OASIS and HCaTS Sales Reporting to SRP
GSA announced that it will transition OASIS and HCaTS contracts from the Contract Payment Reporting Module (CPRM) to the Sales Reporting Portal (SRP). According to GSA, the transition is intended to align OASIS and HCaTS with other Federal Acquisition Service (FAS) contract vehicles, including OASIS+, Polaris, and the Multiple Award Schedule (MAS), which already use SRP for sales reporting and Contract Access Fee (CAF) remittance.
GSA expects OASIS contracts to transition to SRP on or about July 8, 2026, with HCaTS contracts following on or about July 31, 2026. CPRM will be locked approximately 10 days before each migration, and GSA plans to provide additional implementation details and training opportunities ahead of each transition.
Following the migration, contractors will continue reporting task order award data within 30 days of award and remitting quarterly Contract Access Fees through Pay.gov via SRP. Users will be required to access SRP using a FAS ID account with multi-factor authentication.
To help prepare industry partners for the transition, GSA will host SRP training sessions on July 15, August 12, and September 9. Registration information can be found in the announcement. GSA also encourages contractors to verify that contract points of contact are current, ensure key personnel are prepared to obtain FAS ID accounts, and monitor future communications regarding the transition.
Senate FY27 NDAA Includes Proposed CMMC Grant Program
Federal News Network reports that the Senate’s version of the FY27 National Defense Authorization Act (NDAA) includes a provision establishing a grant program to help small businesses and nontraditional defense contractors offset the costs of complying with the Cybersecurity Maturity Model Certification (CMMC) program. CMMC verifies that Department of War contractors meet cybersecurity requirements for protecting controlled unclassified information (CUI).
Under the proposal, eligible organizations could receive grants of up to $100,000 to cover the direct costs associated with a CMMC Level Two Certified Third-Party Assessor Organization (C3PAO) assessment. The bill would prioritize organizations that have not previously held a Department of War contract or subcontract, and the total funding available for the grant program would be capped at $50 million.
The Coalition will continue to monitor this provision as the FY27 NDAA advances through the legislative process.
Senate Advances OTA Transparency Legislation
Federal News Network reports that the Senate has passed the Stop Secret Spending Act, legislation that would require federal agencies to publicly disclose Other Transaction Agreement (OTA) awards through USASpending.gov. In addition, the Senate’s FY27 National Defense Authorization Act (NDAA) includes a provision requiring the Department of War to publish OTA spending data on USASpending.gov.
According to the Government Accountability Office (GAO), agencies obligated approximately $18.2 billion through OTAs in fiscal year 2025. The Department of War recently made the use of Commercial Solutions Openings and Other Transactions the default for all software development components.
The House companion bill to the Stop Secret Spending Act was unanimously approved by the House Committee on Oversight and Government Reform in March.
GSA Provides OASIS+ Scope Review Update and Adds 100 New FAQs
GSA announced that the OASIS+ Scope Review Form available through the OASIS+ Buyer’s Guide is currently unable to accept attachments. GSA is working to resolve the issue and, in the meantime, agency Professional Services Advisors (PSAs) will assist with submitting any required attachments for scope review requests.
As scope review requests are received, the assigned PSA will contact the requesting agency by email to collect the necessary attachments. GSA encourages agencies to respond promptly, as delays in providing the requested materials may affect the timeliness of the scope review process.
GSA also announced that it has added 100 new questions and answers to the FAQ section of the OASIS+ Solicitations (Continuously Open) webpage. Vendors are encouraged to review the updated FAQs before submitting questions, as many common topics have already been addressed. GSA noted that the FAQs will continue to be updated on a rolling basis.
If additional questions remain after reviewing the FAQs, vendors should submit inquiries using the Q&A feature within the OASIS+ Submission Portal (OSP). Questions related to portal registration or technical support should be directed to the OSP help desk.
VA Signals AI, Modernization Expectations for IT Contractors
According to FedScoop, the Department of Veterans Affairs (VA) expects contractors to demonstrate modernization and AI capabilities to remain competitive for agency work. Zack Schwartz, Principal Deputy Assistant Secretary in the VA’s Office of Information and Technology (OIT), said the agency will conduct ongoing reviews across all contracts, noting that incumbency and contract length will not ensure continuation.
Recent progress in the Electronic Health Record Modernization (EHRM) initiative is generating new contracting activity nationwide. Supported by $177.7 billion in fiscal year spending, the VA is “fully engaged” with GSA contracting vehicles and indicated these expectations will be reflected in future awards and evaluations.
Save the Date for the Coalition’s 2026 Fall Training Conference
The Coalition’s 2026 Fall Training Conference will take place on November 18–19, 2026 at the Fairview Park Marriott in Falls Church, VA, bringing together government and industry leaders to discuss the latest developments in governmentwide and healthcare procurement. This two-day event will feature insights from key government decision makers and industry experts on the issues shaping today’s dynamic federal procurement landscape.
The Coalition is also excited to announce that former Congressman and current Holland & Knight partner Tom Davis will deliver keynote remarks on the 2026 election results. In addition, Moshe Schwartz, Coalition Defense Fellow and President of Etherton and Associates, will return to provide his popular legislative and budget update.
Sponsorship opportunities are now available and are currently being secured. Organizations interested in showcasing their brand and supporting this premier procurement event are encouraged to review the 2026 Fall Training Conference Sponsorship Prospectus for additional information. If you have any questions or are ready to secure your sponsorship, please contact Heather Tarpley at htarpley@thecgp.org.
Stay tuned for additional information on conference registration, which will be announced later this summer.
Thank You to Our Current Fall Training Conference Sponsors!
Executive Orders Advance Federal Quantum Initiatives
FedScoop reports that a pair of executive orders (EOs) signed this week aim to accelerate federal adoption of post-quantum cryptography and support the U.S. quantum computing industry. Quantum computing has the potential to solve certain complex computational problems significantly faster than traditional computers, creating new cybersecurity challenges and opportunities.
The first EO, “Securing the Nation Against Advanced Cryptographic Attacks,” directs federal agencies to migrate to post-quantum cryptography (PQC) systems by 2030, five years earlier than the previously established deadline. The order requires all “high value assets,” as designated under Office of Management and Budget (OMB) Memorandum M-19-03, to transition to PQC and directs agencies to support critical infrastructure owners in their own migration efforts.
The second EO, “Ushering in the Next Frontier of Quantum Innovation,” is intended to strengthen the domestic quantum computing industry by reducing regulatory barriers and leveraging federal financing tools to support research, development, and commercialization of quantum technologies.
GAO Recommends Lead Agency for Eligibility Data Standards
In a recent report, the Government Accountability Office (GAO) found no single federal entity has authority to set and enforce governmentwide standards for recipient eligibility data, leading to fragmented oversight and limited interoperability. GAO recommends Congress consider designating a lead agency, potentially the Treasury Department, to coordinate standards and implementation.
Federal agencies rely on more than 100 data sources to verify eligibility, but GAO identified data quality issues across all reviewed systems, including missing, duplicate, inconsistent records, and insufficient validation rules. These issues limit data matching across systems and complicate identification of potentially ineligible recipients.
Under GAO’s proposal, the Treasury would coordinate with the Chief Data Officer Council and consult with the Office of Management and Budget as needed. GAO said improved data standardization could strengthen eligibility determinations and support AI and advanced analytics, warning agencies will continue to face inefficiencies without a designated lead.
Off the Shelf: The FAS Reorganization
Rob Burton, Partner at Crowell & Moring, joined Off the Shelf to discuss the reorganization of GSA’s Federal Acquisition Service (FAS) and what it means for the federal acquisition community.
During the discussion with Coalition President Roger Waldron, Rob breaks down the new FAS structure, including the six offices: Create, Deliver, Assist, Centralize, Optimize, and Transform. He also highlights how the newly established Transform office will focus on AI procurement and implementation.
In addition, the discussion covers the status of NASA SEWP, the next steps for the Revolutionary FAR Overhaul, and the government’s current procurement policy priorities.
Listen to the full podcast here.
Legal Corner – Warp Speed Ahead: Agencies Move Quickly to Implement Anti-DEI Clause
The Legal Corner provides the procurement community with an opportunity to share insights and comments on Legal issues of the day. The comments herein do not necessarily reflect the views of The Coalition for Common Sense in Government Procurement.
By Keeley McCarty, Robbie Pratt, Jaeho Lee & Jacob Green; Fox Rothschild LLP
Contractors have begun receiving modifications to existing contracts implementing the new DEI clause mandated by Executive Order 14398 “Addressing DEI Discrimination by Federal Contractors.” Shortly after the executive order, the FAR Council issued a Memorandum[1] establishing a new implementing clause, FAR 52.222-90.
The Memorandum also established mandatory deadlines for agencies to begin including FAR 52.222-90 in federal procurements:
- April 24, 2026: Agencies were required to begin inserting FAR 52.222-90 in new solicitations and resulting contracts. They were also required to amend any open solicitations to incorporate the clause in accordance with FAR Part 1.107(d) by this date.
- July 24, 2026: Contracting officers must make every effort to bilaterally modify existing contracts, including definitive contracts and indefinite-delivery contracts, to include FAR 52.222-90 by this date.
It appears that at least some agencies are on schedule, as the new clause has begun appearing in solicitations and contracting officers are now pushing out bilateral modification requests to add the clause to their existing contracts. In some cases, modifications are bundling the new clause with other contract changes, so contractors should read proposed modifications closely in the coming months.
In deciding whether to accept the new clause, contractors should consider a few key points:
- FAR 52.222-90 prohibits race- and ethnicity-based disparate treatment in recruitment, hiring, contracting, program participation, or allocation of company resources. This prohibition overlaps somewhat, but not completely, with existing federal anti-discrimination laws. Specifically, contractors should evaluate whether they employ any race- or ethnicity-based contracting preferences or allocations of resources on their federal contracts that might violate the clause.
- The clause limits its applicability to conduct “[i]n connection with the performance of work under this contract,” so conflicting requirements on unrelated state contracts should not preclude compliance.
- FAR 52.222-90 will apply to all solicitations and contracts valued above the micro-purchase threshold where the United States is the place of performance or delivery. The new clause will also apply to procurements for commercial products and services.
- The clause requires contractors to flow it down to subcontracts at all tiers, including subcontracts for commercial products and services. Contractors must report subcontractor non-compliance with the clause, which means contractors should consider how they will monitor subcontractor compliance and document the process in their files.
- While the Memorandum directs contracting officers to “make every effort” to bilaterally modify existing contracts to add FAR 52.222-90, it also encourages contracting officers to terminate the contract if the contractor will not agree to modify willingly, provided the contracting officer determines that the contract no longer meets the agency’s needs.
- There are several ongoing legal challenges to the new clause and underlying executive order, but for now the clause is valid and enforceable once incorporated into a contract.
Contractors can expect some pressure from the government to add FAR 52.222-90 to their contracts, especially given the available threat of contract termination if they decline. But contractors should make sure they understand the implications before signing and pay close attention to other content of the requested modification. Contractors should also prepare to flow down the new clause and monitor subcontractor compliance. Failure to do so may lead to suspension, debarment, and potential civil FCA exposure.
[1] Agency Implementation of Executive Order 14398, Addressing DEI Discrimination by Federal Contractors.