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When the Heck Do I Need to File a Disclosure Statement?

Thursday, 01 October 2026 08:09 Nick Sanders

After literally years of moving at the pace of molasses being poured at the North Pole, recently the CAS Board decided to make changes to the Standards, the Exemptions, and the rules of CAS applicability. Because the rules regarding thresholds at which Modified and Full Coverage applies have changed, that means the rules regarding when you have to file your first Disclosure Statement have also changed. Let’s discuss, shall we?

In my experience, the Disclosure Statement is feared by smaller contractors like Winterfell feared the White Walkers. It’s a difficult document, made even more difficult by the fact that the “official” version is an editable .pdf thing that’s as easy to edit as a it is to carry a king-size mattress up a narrow spiral staircase. The fact that the form hasn’t been updated since February, 1996—literally 30 years ago!—doesn’t make it any easier.

I know of contractors who have literally turned-down contract awards because they were going to have to file a Disclosure Statement if they accepted them. No, really. They would rather turn-away business than have to file a Disclosure Statement. Sigh.

A Disclosure Statement is not something to be feared if you approach it correctly. Unfortunately, unless you know, you don’t know and then it’s a fluster cluck. So, let me explain in one simple sentence: it takes a multi-functional team to accurately and efficiently prepare an adequate Disclosure Statement. That’s it. That’s all it takes. But companies don’t, as a rule, approach the project in that manner. They give the project to Accounting because it’s primarily a disclosure of cost accounting practices, and Accounting handles cost accounting, right? Never mind all the questions about insurance programs and direct versus indirect determinations and treatment of certain transactions and capitalization versus expensing and the other myriad details that comprise a Disclosure Statement. Just give it to Accounting; make it be their problem. And thus, you get a stalled project or one with multiple errors in it.

So, don’t do that. Get a team together: contracts, legal, risk/insurance, pricing/estimating, accounting, and as many other functions as you need. Throw a good project manager in there as well, not to manage the project but to listen for bad practices that will negatively impact company projects. Have them discuss the questions as a team. Get consensus answers that work for the entire company. If you do that, when DCAA shows up, you’ll have great answers for any questions the auditors may have.

Or not. Depends on what outcome you want, I guess.

But when do you have to file the curs’d thing? The rules used to be known. They were complex, sure, but DCAA had a nifty flowchart that walked you through what you needed to know to make the right decisions. Now we have “Increase of Monetary Thresholds and Other Matters Related to Cost Accounting Standards Program Requirements,” which is a Federal Register Notice (91 FR 56056) dated 01 September 2026. That’s all we have because www.acquisition.gov, which is the official U.S. Government website for acquisition regulations (and CAS), hasn’t been updated yet.

Based on the Federal Register Notice, here are the new rules.

You need to submit a Disclosure Statement when you win a CAS-covered contract valued at $100 million or more, or when you received $100 million or more in net CAS-covered awards during your preceding cost accounting period (fiscal year).

You do NOT need to file a Disclosure Statement if your business unit received less than $100 million in CAS-covered awards, even if your company did. This is significant! The rules used to say—

Any company which, together with its segments, received net awards of negotiated prime contracts and subcontracts subject to CAS totaling $50 million or more in its most recent cost accounting period, must submit a Disclosure Statement before award of its first CAS-covered contract in the immediately following cost accounting period. However, if the first CAS-covered contract is received within 90 days of the start of the cost accounting period, the contractor is not required to file until the end of 90 days.

Now, that paragraph says—

Any business unit or segment, received net awards of negotiated prime contracts and subcontracts subject to CAS totaling $100 million or more in its most recent cost accounting period, must submit a Disclosure Statement before award of its first CAS-covered contract in the immediately following cost accounting period. However, if the first CAS-covered contract is received within 90 days of the start of the cost accounting period, the contractor is not required to file until the end of 90 days.

But that’s not all.

The CAS rules used to have separate directions regarding when a business unit needed to submit a Disclosure Statement. The rules said—

When a Disclosure Statement is required, a separate Disclosure Statement must be submitted for each segment whose costs included in the total price of any CAS-covered contract or subcontract exceed the Truth in Negotiations Act (TINA) threshold, as adjusted for inflation (41 U.S.C. 1908 and 41 U.S.C. 1502(b)(1)(B)) unless

(i) The contract or subcontract is of the type or value exempted by 9903.201-1 or

(ii) In the most recently completed cost accounting period the segment's CAS-covered awards are less than 30 percent of total segment sales for the period and less than $10 million.

Yeah, that’s a lot. But don’t worry about it. That entire paragraph (48 CFR 9903.202-1(c)) is now gone. Eliminated in its entirety! (Well “reserved” – but we all know what that means.) As a result, of the change to 9903.201-2(b)(2) and the elimination of 9903.202-1(c), what matters is the dollar value of the contract(s) the business unit receives, not what the company receives. I know several smaller business units of large companies that should be dancing a happy dance right now.

Modified CAS coverage is still an option, for contractors that receive $35 million or more but less than $100 million in CAS-covered contracts. Remember, you must elect Modified coverage in your Section K of your Reps & Certs. It’s not automatically given.

There’s even a new rule for contractor that were subject to Full CAS coverage under the old threshold ($50 million) but wouldn’t be subject to Full coverage under the new ($100 million) threshold. If you fall into that category, you can transition your affected contracts or subcontracts to Modified coverage at the start of the business unit's next full cost accounting period (fiscal year) beginning on or after October 1, 2026, provided the business unit:

(i) Has no unresolved CAS noncompliances; and

(ii) Does not meet the criteria for full CAS coverage using the $100 million threshold in effect as of October 1, 2026.

If you qualify for Modified coverage under rule #5 (above), then you can certify eligibility for Modified coverage in your Section K Reps & Certs for new solicitations and awards on or after October 1, 2026. If you don’t qualify, then sorry.

Moreover, the 14 September 2026 Department of War Memo “Fostering One Strong Industrial Base” tells Contracting Officers that they should look at compliance requirements and—

To the maximum extent permitted by law and contract, [ ] cease enforcing superseded requirements, and contracting officers will offer bilateral no-cost modifications removing affected clauses at the next practicable opportunity.

That direction seemingly applies to business systems but I see no reason it can’t apply to CAS, as well. If you have a contract that would not be subject to CAS under the new regime, or if you have a contract with CLINs that would not be subject to CAS under the new regime, it’s probably worth your time to ask your Contracting Officer to issue that no-cost bilateral modification to bring your contract in line with current requirements.

So, those are the rules as I see ‘em. Any questions? Send me an email … This e-mail address is being protected from spambots. You need JavaScript enabled to view it .

Recent CAS Changes

Tuesday, 15 September 2026 18:06 Nick Sanders

Hey! Lots of changes to the Cost Accounting Standards over the past couple of years. After literally decades of incremental movement, the Standards changed in what seemed like lightening speed. To help me summarize the changes, I created the table below. I hope it helps you, as well. Also, if you see anything I missed, please email me at This e-mail address is being protected from spambots. You need JavaScript enabled to view it .

CAS Changes

As of September 2026

No.	Description	Change	Reference	Comment

401	Consistency in Estimating, Accumulating, Reporting Costs	No change	48 CFR 9904.401
402	Consistency in Allocation Costs Incurred for the Same Purpose	No change	48 CFR 9904.402
403	Allocation of Home Office Expenses to Segments	Slight Change	90 FR 43942, (09/11/2025)	For 3FF, now use “revenue” as per GAAP, not “operating revenue”
404	Capitalization of Tangible Capital Assets	Rescinded	91 FR 42139 (07/23/2026)	404-50(d)(1) moved to 405-40(g)
405	Accounting for Unallowable Costs	Slight Change	91 FR 42139	Added 405-40(g) from 404-50(d)(1)
406	Cost Accounting Period	No Change	48 CFR 9904.405
407	Use of Standard Costs for Direct Material and Direct Labor	Rescinded	91 FR 56061 (09/01/2026)	Moved “production unit” and discussion of standard costs to CAS 418
408	Accounting for Costs of Compensated Personal Absence	Rescinded	91 FR 42139	Changes not subject to impact analysis but must be disclosed within same year
409	Depreciation of Tangible Capital Assets	Rescinded	91 FR 42139	409-50(e)(5), 409-50(j)(1), 409-50(j)(4) moved to 405-40(g)
410	Allocation of Business Unit G&A Expenses to Final Cost Objectives	No change	48 CFR 9904.410
411	Accounting for Acquisition Costs of Material	Rescinded	91 FR 42139	Rescinded in its entirety
412	Composition and Measurement of Pension Cost	No change	48 CFR 9904.412
413	Adjustment and Allocation of Pension Cost	No change	48 CFR 9904.413
414	Cost of Money as an Element of the Cost of Facilities Capital	No change	48 CFR 9904.414
415	Accounting for the Cost of Deferred Compensation	No change	48 CFR 9904.415	Will be subject to future rulemaking
416	Accounting for Insurance Costs	No change	48 CFR 9904.416	Will be subject to future rulemaking
417	Cost of Money as an Element of the Cost of Capital Assets Under Construction	No change	48 CFR 9904.417
418	Allocation of Direct and Indirect Costs	Slight Change	91 FR 56061	Added definition of “production unit” from CAS 407; added discussion of standard costs; added illustration at 418-60(j)
420	Accounting for IR&D and B&P Costs	No change	48 CFR 9904.420

Moving at the Speed of Bureaucracy

Thursday, 03 September 2026 06:10 Nick Sanders

People within the Federal acquisition environment are rightly pleased to see the July 2026 reforms to the Cost Accounting Standards via publication of a final rule that became effective 07 August 2026. (See 91 FR 42139.) The reforms:

Eliminated CAS 408 (Compensated Personal Absence) in its entirety
Eliminated CAS 411 (Acquisition Costs of Material) in its entirety
Significantly reduced requirements of CAS 404 (Capitalization of Tangible Assets) and CAS 409 (Depreciation of Tangible Capital Assets). The Standards were eliminated but a few parts were moved to other existing Standards.

At this point, instead of 19 Standards, we have 15. Yay! Good for us all.

Except why did it take so long?

Let’s review the history of this rulemaking action. Congress first told the CAS Board to take action via Section 820 of the 2017 National Defense Authorization Act (NDAA). That was literally nine years ago. Two years later, the CAS Board published a Staff Discussion Paper (SDP) in March 2019, to establish a “a global roadmap to help guide [the Board’s] approach to conformance” of CAS and GAAP. That roadmap identified seven standards (404, 407, 408, 409, 411, 415, and 416) as most suitable for potential conformance to GAAP. Apparently, the Board is still working on Standards 415 and 416, as they were not part of the July 2026 final rule.

Eighteen months later (18 September 2020), the Board published another SDP “to solicit views with respect to the Board's initial assessment of CAS 404 and CAS 411….”

A formal Advanced Notice of Proposed Rulemaking (ANPRM) was issued 27 June 2024 to address Standards 408 and 409. Not quite four years after the SDP was issued and public comments received. The comments were sufficient to convince the Board that the two Standards were ripe for reform.

Another formal ANPRM was published 17 January 2025 to address the Board’s conclusions on Standards 404 and 411. Literally more than four years after the second SDP was published.

Four years. Let that sink in.

Yeah, yeah, yeah. Right. There was a slight COVID-19 interruption. There was a lack of an industry Board member. The CAS Board Chair was “acting” because there was no Senate-confirmed OFPP Administrator. All true. Valid points. But also just excuses because the business of the Federal government shouldn’t be paused for FOUR YEARS because some folks lost the keys to the file cabinet. Or so it seems to us here at Apogee Consulting, Inc.

The next step in the CAS rulemaking process, a formal Notice of Proposed Rulemaking (NPRM), was published 11 September 2025 to address all four Standards: 404, 408, 409 and 411. That was what? Less than two years after one ANPRM and less than one year after the other one. That was quick, given the historical bar established by the Board.

So now we have a Final Rule, published 08 July 2026. Less than a year after the NPRM. Super quick, right?

Only let’s not forget that the original SDP was published in 2020. We don’t think six years is a timeline in which to take pride.

The Department of War wants its forces to “move at the speed of relevance.” It has concluded that the old paradigms must give way to new ways of operating. From an article by Robbin Laird dated 31 March 2026 at www.defenseinfo.com.

Where armies and policymakers once relied on warning times and slow mobilization, they now confront adversaries, technologies, and social currents that move at the speed of relevance, upending the calculus of deterrence and defense planning.

Against this backdrop, the central strategic imperative is no longer to eliminate chaos or restore some lost order, but to build national systems, forces, and cultures that thrive amid it.

The security of the twenty-first century will belong to those who master the art of chaos management: sensing, adapting, and responding rapidly to events, even as crises multiply and old frameworks collapse.

Sense; adapt, respond. Do it quickly. Cool, cool, cool.

Only the CAS Board doesn’t seem to have gotten the message. They seem to be moving at the speed of bureaucracy rather than the speed of relevance.

Let’s be clear: reforming the CAS is a good thing. We applaud it. Only—why did it take so freaking long to accomplish?

One possible reform: the CAS Board has no timeline in which to take action. The Board can let the public input from SDPs and ANPRMs and NPRMs lie fallow for years because it can and because nothing forces the Board to move forward. Let’s reform the enabling statutes to require Board action within six months of public comment period closure. If you did that, we bet you’d see some real speed.

Last Updated on Thursday, 03 September 2026 07:05

CAS Applicability (48 CFR 9903.201-1(b))

Sunday, 13 September 2026 17:27 Nick Sanders

Summary of Changes

	Pre-2026 CAS Exemptions	Revisions (91 FR 56056, 09/01/2026)
1	Sealed bid contracts	No change
2	Negotiated contracts and subcontracts not in excess of the Truth in Negotiations Act (TINA) threshold *	Negotiated contracts and subcontracts not in excess of $35 million
3	Contracts and subcontracts with small businesses	No change
4	Contracts and subcontracts with foreign governments or their agents or instrumentalities or any contract or subcontract awarded to a foreign concern **	No change
5	Contracts and subcontracts in which the price is set by law or regulation	No change
6	Contracts and subcontracts authorized in 48 CFR 12.207 for the acquisition of commercial items	Contracts and subcontracts (or the portion of a contract or subcontract) for the acquisition of commercial products or commercial services
7	Contracts or subcontracts of less than $7.5 million, provided that, at the time of award, the business unit of the contractor or subcontractor is not currently performing any CAS-covered contracts or subcontracts valued at $7.5 million or greater	Subcontractors under the NATO PHM Ship program to be performed outside the United States by a foreign concern
8	Reserved	Firm-fixed-price contracts or subcontracts (or the portion of a contract or subcontract) awarded on the basis of adequate price competition without submission of certified cost or pricing data
9-12	Reserved	Eliminated
13	Subcontractors under the NATO PHM Ship program to be performed outside the United States by a foreign concern	Moved to (b)(7)
14	Reserved	Eliminated
15	Firm-fixed-price contracts or subcontracts awarded on the basis of adequate price competition without submission of certified cost or pricing data	Moved to (b)(8)
Notes:	* The TINA threshold historically has been adjusted for inflation. Was $2.5 million but is now $10 million per 2026 NDAA. Also, for purposes of paragraph (b)(2), an order issued by one segment to another segment is to be treated as a subcontract. The mandated treatment of inter-segment orders was not revised by the 01 Sept 2026 changes. ** Contracts or subcontracts awarded to a foreign concern may be subject to CAS 401 and 402. (But see the exemption at (b)(13).)

Applicability to Indefinite Delivery type contracts

Application of exemptions to indefinite delivery contracts shall be determined as follows:

(1) Multiple-award indefinite delivery contracts. The exemptions shall be determined at the time of award of any individual task or delivery order, and shall use the ceiling value of the individual task or deliver order to determine if the monetary threshold in (b)(2) has been met.

(2) Single-award indefinite delivery contracts. The exemptions shall be determined at the time of award of the indefinite delivery contract, and shall use the ceiling value of the indefinite delivery contract to determine if the monetary threshold in (b)(2) has been met. An entire single-award indefinite delivery contract is exempt if it only provides for the ordering of commercial products or commercial services, or only provides for ordering on a firm-fixed-price basis and the indefinite delivery contract was awarded on the basis of adequate price competition without the submission of certified cost or pricing data.

What Does All This Mean to You?

The September 2026 revisions create the ability to “carve out” pieces of awarded contracts that would otherwise be subject to CAS coverage. Two “carve-outs” are available: (1) Portions of contracts for acquisition of commercial products or services, and (2) Portions of contracts that are firm, fixed-price and awarded without submission of certified cost or pricing data. This concept also applies to task/delivery orders awarded under ID/IQ-type contracts, or to an entire ID/IQ-type contract if it was awarded on a single-source basis.

Commercial products and commercial services are defined at FAR 2.101.

Commercial product means—

(1) A product, other than real property, that is of a type customarily used by the general public or by nongovernmental entities for purposes other than governmental purposes, and–

(i) Has been sold, leased, or licensed to the general public; or

(ii) Has been offered for sale, lease, or license to the general public;

(2) A product that evolved from a product described in paragraph (1) of this definition through advances in technology or performance and that is not yet available in the commercial marketplace, but will be available in the commercial marketplace in time to satisfy the delivery requirements under a Government solicitation;

(3) A product that would satisfy a criterion expressed in paragraph (1) or (2) of this definition, except for-

(i) Modifications of a type customarily available in the commercial marketplace; or

(ii) Minor modifications of a type not customarily available in the commercial marketplace made to meet Federal Government requirements. “Minor modifications” means modifications that do not significantly alter the nongovernmental function or essential physical characteristics of an item or component, or change the purpose of a process. Factors to be considered in determining whether a modification is minor include the value and size of the modification and the comparative value and size of the final product. Dollar values and percentages may be used as guideposts, but are not conclusive evidence that a modification is minor;

(4) Any combination of products meeting the requirements of paragraph (1), (2), or (3) of this definition that are of a type customarily combined and sold in combination to the general public;

(5) A product, or combination of products, referred to in paragraphs (1) through (4) of this definition, even though the product, or combination of products, is transferred between or among separate divisions, subsidiaries, or affiliates of a contractor; or

(6) A nondevelopmental item, if the procuring agency determines the product was developed exclusively at private expense and sold in substantial quantities, on a competitive basis, to multiple State and local governments or to multiple foreign governments.

Commercial service means—

(1) Installation services, maintenance services, repair services, training services, and other services if–

(i) Such services are procured for support of a commercial product as defined in this section, regardless of whether such services are provided by the same source or at the same time as the commercial product; and

(ii) The source of such services provides similar services contemporaneously to the general public under terms and conditions similar to those offered to the Federal Government;

(2) Services of a type offered and sold competitively in substantial quantities in the commercial marketplace based on established catalog or market prices for specific tasks performed or specific outcomes to be achieved and under standard commercial terms and conditions. For purposes of these services–

(i) Catalog price means a price included in a catalog, price list, schedule, or other form that is regularly maintained by the manufacturer or vendor, is either published or otherwise available for inspection by customers, and states prices at which sales are currently, or were last, made to a significant number of buyers constituting the general public; and

(ii) Market prices means current prices that are established in the course of ordinary trade between buyers and sellers free to bargain and that can be substantiated through competition or from sources independent of the offerors; or

(3) A service referred to in paragraph (1) or (2) of this definition, even though the service is transferred between or among separate divisions, subsidiaries, or affiliates of a contractor.

Got all that? Good. Look for opportunities to claim commerciality. If your customer agrees with you, then the value of that part of your contract should be subtracted from the total awarded price (which assumes all priced options are exercised) in order to determine the contract value for the purpose of determining CAS applicability.

Same thing for FFP items awarded without submission of certified cost or pricing data. This one will be a bit trickier. This “carve-out” is more under your control, because you know whether you submitted certified cost or pricing data. But what may not be obvious is that you can submit certified cost or pricing data (along with the requisite Certification of Cost or Pricing Data, or CCPD) for some parts of your contract but not for other parts. Therefore, you will need to distinguish such goods or services from the rest of the contract, and make sure your TINA certification expressly excludes those goods or services. That will be a bit tricky, because it’s easier to just submit one CCPD for the contract rather than submit an annotated CCPD with certain clear exclusions.

In addition, your contract briefs (you do prepare contract briefs, don’t you?) will need to distinguish CAS-covered from non-CAS-covered portions of the awarded contract. If you use databases for contract documentation/retention, you will need to make sure your databases permit this identification.

In summary, your ability to use these “carve-outs” largely will depend on the ability of your cost estimators and pricers to identify them and obtain customer buy-in during negotiation. But if your contract value is on the cusp of a CAS coverage threshold, it will be worth the effort.

Afterward—and assuming success—the burden will shift to your accounting team to distinguish these items in the incurred cost submission (aka Proposal to Establish Final Billing Rates). Obviously, the best (and easiest) way to identify the carve-out contract pieces will be through separate CLINs (Contract Line Item Numbers) or maybe even SLINs. You will need to do something like that because, if they disappear into your contract, then you have no ability to show an auditor which pieces of your contract are subject to CAS and which are not. You will have thrown away the flexibility provided by the CAS Board.

In practice, contractors will need tight coordination between cost estimators, pricers, and accountants (as well as audit support staff) in order to execute this effort cleanly. It should be possible, and savvy contractors will make the effort to develop appropriate policies, procedures and practices to make it happen.

Calm in the Midst of Chaos

Thursday, 29 May 2025 19:31 Nick Sanders

Take_a_Breath Hello. It’s been a while, hasn’t it? If you are one of the people who keep coming back to this site, to see if I’ve blogged anything new—or maybe to check out one of the far-too-many articles in the News Archive—then thank you. I’m writing this for you, because I have something to say.

I haven’t blogged about the problematic CAS cost impact guidance issued in late 2023 by DCAA and publicly endorsed by DCMA. If you’re dealing with that, you have my sympathies. And my apologies, because I was one of those who pointed out to DCAA that their then-current audit guidance didn’t comport with the 2015 Raytheon decision at the ASBCA. Well, I got what I wanted—and then some. DCAA updated their audit guidance and took that opportunity to take a little extra along the way. But I didn’t write about that because what can one do except hope that some contractor wronged by inapt audit guidance takes the DOD to court.

I haven’t blogged about recent CAS Board activity, because why get all hot and bothered about things that may never come to pass or things that may be overtaken by events (clears throat **Executive Order**). CAS 404, 408, 409 and 411 are in play at the CAS Board but, as most everyone knows, the Board is currently adrift, waiting for direction and, dare I say, leadership that is currently lacking. The many Staff Discussion Papers, Advance Notices of Proposed Rulemaking and Notices of Proposed Rulemaking may someday result in regulatory action. Maybe. But until then, it’s business as usual. So, I didn’t write about all that CAS stuff.

I haven’t blogged about the recently announced DCAA reorganization, which seems to affect only the very largest of DOD contractors, the ones that my friend John used to call “the Five Families.” And the auditors, of course. They are impacted. But the rest of us? Not so much. So what could I have said?

I haven’t blogged about cyber-security and the recent updates in requirements, nor have I blogged about CMMC and are you ready to be assessed? because, at this point, if you don’t know you have already lost the race. I mean, it’s not like I have ignored the topic. For more than a decade I have been beating the drums of cyber-security and secure supply chains. I’m tired now; my arms hurt from all that drumming and I don’t have the energy to keep telling people what they should already know.

Today’s blog article is about FAR 2.0 and regulatory reform. Many people are anxious about what FAR 2.0 will look like and how it might affect them. What does government contract compliance look like in an environment where all the regulations—which have been growing and evolving and changing since 1984—are eviscerated into something that looks nothing like what we thought we knew? What will that be like? So, there is anxiety and nervousness.

I want to suggest that we all calm down. Relax. Wait and see. Not knowing makes us nervous—true. I get that. The uncertainty can be hard on one’s nerves. But consider: don’t worry about the unknown future because we have quite enough on our plates right now. Deal with today and let tomorrow take care of itself.

Here are some absolute truths that you may wish to consider as you contemplate what may transpire:

You have existing contracts. They have clauses in them and those clauses impose requirements. They will exist until the work is physically complete and delivered and accepted. They will exist until the final billing rates are calculated and submitted and audited and negotiated. They will exist until the final invoices are submitted and paid. In other words, they will exist for a long time and, at least for those contracts, nothing is going to change. Nothing. All the risks are still the same: compliant timekeeping, compliant accounting, compliant billing, compliant purchasing. Et cetera. The False Claims Act and The Truthful Cost or Pricing Data Act still apply.

You have proposals in the pipeline. Some of those competitions may be cancelled, especially if you are at one of those contractors that perform touchy-feely work not aligned with current Washington, DC, priorities. True. But many others will not be cancelled, especially for those DOD contractors that provide critical weapon systems. Those contractors actually may experience a bit of an uptick. (Historical analog: the defense buildup under Reagan.) Those RFPs still have their provisions in place; the evaluation factors are still the evaluation factors. For current proposals, nothing is going to change. Nothing.

Future contracts and future proposals may look different—true. But how different? What will they look like? We don’t know … so try not to worry about it. There are bills being discussed in Congress that may change things, but those bills still have to go through Committee votes and reconciliations and all the other things that make the actual lawmaking impenetrable to most humans. There may be legal challenges to whatever final laws emerge from the morass of Congressional lawmaking. We don’t know what the end-product will look like or what parts will be voided by the courts … so let’s wait and see what emerges, if anything.

I listen to some smart and experienced people, such as Vern Edwards and Jim Nagle. They’re not worried. They’ve been through this before. (Implementation of FASA in the mid-nineties comes to mind.) Most people do not think much is going to come of the current FAR 2.0 efforts. They are, let’s say, dubious. Vern said (in a podcast which is available at WIFCON 2.0) that he doesn’t think anything significant is going to happen “but it’s going to be fun watching.” That’s a good attitude to have, if you can get there.

So … those are four truths that I hope will help calm you and your work teams.

Let’s be honest here. There have already been significant changes at the government workforce and funding levels. Those changes are starting to have ripple effects at the contractors. Those impacts will definitely continue. I’m not blind to them and, for many (especially those in civil service) it’s going to be tough. But you can get through this, especially if you are flexible and willing to take some risks.

There are jobs aplenty, especially in the manufacturers of weapon systems. But the jobs might not be available near you, especially if you had a nice remote work gig. You may have to move in order to find employment. So what? I’m not trying to trivialize the pain of moving one’s family, because it is a pain. I know. (I’ve moved my family three times and that doesn’t count my move from LA to Fairfax, VA when I was single.) But you can do it—especially if you need to.

Almost everyone who reads this blog has skills that are important to government contractors. Get out there: polish your resume; update your LinkedIn profile. And start applying. Will you have mixed results? Probably. But don’t give up because I know—I know—that contractors are looking for good people with skills and experience. I work at one of them and we are desperate for the right people to apply to our career site.

Think about the priorities in DC right now, which is where the funding will be. Where do your skills fit into those priorities? More FMS cases, more international contracts. Border security; “Golden Dome” (which sounds to me like “Star Wars,” which we called “Peace Shield,” which was among the first projects I worked on when I started in this crazy business.) There is work to be found, so go find it.

All right. Stop rolling your eyes. I don’t know how this article morphed into a rah-rah session. Sorry. But I hope I’m communicated something here: sure, all is chaos. Okay. But if you stay calm and deal with what’s in front of you, you’ll be fine.

Last Updated on Thursday, 29 May 2025 19:49

More Articles...

When the Heck Do I Need to File a Disclosure Statement?

Recent CAS Changes

Moving at the Speed of Bureaucracy

CAS Applicability (48 CFR 9903.201-1(b))

Calm in the Midst of Chaos

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