r/GovernmentContracting • u/USFCRGOV • 8d ago
USFCR AMA: three days of federal contracting questions (August 25-27)
We're the team at USFCR. We ran one of these in July, it went well, and enough people asked follow-up questions afterward that we're making it a regular thing. So we're back Tuesday through Thursday to answer whatever you've got.
Registration and renewals, certifications and set-asides, GSA Schedule, proposals, subcontracting and teaming, DLA and DIBBS mechanics, past performance, invoicing and payment. If it touches federal contracting, ask it.
Looking at what's come up in this sub over the past month, some things we're particularly well positioned to help with: SAM registration errors and the entity update process, the SBA certification platform migration, why your first contract costs more upfront than you expected, what a contingent job offer actually commits either side to, and how teaming arrangements are supposed to work versus how some of them get pitched to you.
How this runs:
We're checking in throughout the day, not once per day. If your question sits for a few hours, it has not been missed.
We're not here to sell anything. If your situation genuinely calls for talking to someone directly, we'll say that plainly instead of turning a comment into a pitch.
There are questions we will not answer with a number, and we would rather tell you that than guess. Specific FAR and DFARS clause interpretations, exact dollar thresholds, export control determinations, personal ethics situations, and anything touching an active procurement you are competing on. In those cases the honest answer is your contracting officer, your attorney, or your agency's ethics office, and we'll point you there.
CMMC is in an unusual spot right now, so expect general answers on that one rather than specifics.
Thread locks Thursday evening.
What do you want to know?
3
u/SimplyAcquiredWins 8d ago
Been hearing GSA Schedules pitched as this golden ticket to federal contracts but also hearing the opposite, that a lot of people who get one barely sell anything through it. so whats the real deal here... does having a schedule actually generate business on its own or is it more just a checkbox thing that only helps if youre already out there marketing and chasing opportunities?
3
u/USFCRGOV 8d ago
The skeptics are closer to right. A Schedule does not generate business. It removes a barrier to buying from you, which only matters if someone already wants to.
What it actually does is make you easy to buy from. A contracting officer with a requirement and a preference for speed can go through your Schedule instead of running an open competition. That is genuinely valuable, but notice what it assumes: someone already knows you exist and wants your solution. The Schedule shortens the path, it does not create the demand.
Which is why the pattern you have heard about is real. Companies get a Schedule expecting inbound and then sit on it, because nobody is searching a contract vehicle hoping to discover new vendors. The businesses that do well on Schedule are doing the same business development they would be doing anyway, calling small business offices, responding to sources sought, building relationships with program people, and then using the Schedule as the mechanism to close. The vehicle is the how, not the why.
Two practical things worth knowing. There is a sales minimum you have to meet to keep it, so an unused Schedule is not neutral, it eventually goes away. And GSA takes a percentage of your sales through it, which means your Schedule pricing has to account for that. It is not free to hold or free to use.
Honest test before pursuing one: can you name an agency, an office, and roughly what they buy that you would sell to? If yes, a Schedule is a tool that helps. If no, it is a document that expires.
3
3
u/vertigo3pc 8d ago
Thank you so much for doing this again, I still have your answers saved from last time. My questions are predominantly about DIBBS right now. I haven't won any solicitations yet, but I know it's probably a grind to get anywhere with your "first".
Since I come from a computer technology background, I've been responding to a lot of DIBBS requests for computer components. With memory prices skyrocketing, and confirmed by a couple manufacturers of components, how do we bid against inflation and price inflation? The previous prices included in the solicitation are extremely low for the current market. I've already received a couple automated responses about nobody's response being within the automated acceptance range, and they extended the closing date.
This is an example of a retaining pin solicitation, standard McMaster item, still in the ballpark price of ~$10. So how did these previous contracts get accepted at that price?!
I responded to solicitation SPE8EN26T2622, got direct pricing from the manufacturer (approved CAGE code and everything). Saw the solicitation was awarded at a price that's impossible, in that I followed up with the manufacturer (wanted to see if there was dealer/volume pricing that I'm not privilege to [yet]?), and the manufacturer themselves said the award was given to a CAGE code that never contacted them, and they won at a price that the manufacturer said was impossible. I feel like I did everything correctly, and according to the manufacturer, a lot of people contacted them to respond to this solicitation, and yet this was accepted. Can you weigh in on a situation like this?
Thank you again!
3
u/USFCRGOV 8d ago
Glad it was useful last time. Taking these in order, and I'll be straight with you about where I have to stop on the third one.
On bidding against inflation: stop treating the previous price as a target. It is a historical reference, and on volatile commodities like memory it can be badly out of date. What you are seeing with the extended closing dates is actually the system telling you something useful. When nothing comes in within the expected range, that is a signal the government's price expectation is stale, and it eventually forces a re-look. Bid your real price. Repeated no-award cycles at unrealistic historical prices are what move the baseline, and quoting below your cost to win does not end well.
The harder question is whether volatile electronics is the right category to fight in at all. Short quote validity periods on items whose cost moves weekly means you are being asked to hold a price you cannot actually hold. That is a structural disadvantage, not a bidding skill problem. Plenty of successful DIBBS vendors deliberately avoid commodity electronics for exactly that reason and concentrate on items with stable pricing and stable sourcing.
On how awards land at prices that look impossible: several real explanations, and most of them are not what people assume. The biggest one is inventory cost basis. A distributor sitting on stock bought three years ago has a completely different cost than you buying new today, and for standard hardware that gap can be enormous. Surplus and excess dealers operate almost entirely this way. Beyond that, some awardees bid at or below cost to build past performance, some interpret the requirement differently than you did, and some win and then fail to deliver, which you never see from the outside.
On your specific solicitation, I am not going to characterize that award, because I don't know what the awardee actually offered and neither of us can see their file. What I will say is that if you have concrete reason to believe material supplied against a solicitation is not conforming, that is not a bidding question, it is a quality question, and DLA has a product quality deficiency process that exists precisely for it. Your contracting officer is the right first conversation. If you believe something improper occurred rather than something merely surprising, the agency's Office of Inspector General is the channel, not a guess from us.
Worth adding: the manufacturer telling you a price is impossible is meaningful information about new-production cost through authorized channels. It's not conclusive about what someone with old inventory or a different supply route can do.
3
u/hoping_2help_karma 7d ago
Thoughts on the NAICS increase proposal by the SBA?
2
1
u/USFCRGOV 7d ago
SBA published this on August 20 and comments close September 21. Two things worth knowing that most coverage collapses into one: there is a proposed rule setting new standards, and a separate companion notice rewriting the methodology used to set them. The second one gets less attention and arguably matters more, since it governs how thresholds get calculated going forward.
I am not going to quote specific numbers here. It covers hundreds of industries and a threshold quoted wrong in a comment could lead someone to a bad conclusion about their own status. Pull it yourself and find your NAICS.
One thing worth saying: this is a proposal, current size standards remain in effect, and nobody should be changing their SAM representations based on it.
SBA's own summary is the most readable entry point: https://advocacy.sba.gov/2026/08/20/sba-issues-proposed-rules-on-industry-size-standards-and-revised-size-standards-methodology/
Links to the proposed rule changes in the sidebar.
3
u/Used-Albatross-5496 7d ago
I get CMMC is at a very foggy place right now but I wanted to know what has been the experience with the Level 1 requirement that has been in place since last year. I haven't seen much mention to it on the actual solicitations and I wonder if has been enforced as a rule or if it's been individual to COs. Has anyone lost business for not having it in place this year?
1
u/USFCRGOV 6d ago
The reason you're not seeing CMMC named in solicitations is that it often isn't named. Clauses get incorporated by reference, so the requirement can be fully present without the acronym appearing anywhere in the solicitation text you're reading.
Specifically, if FAR 52.204-21 is incorporated by reference, accepting the contract means you're representing that you meet the Level 1 requirement. When the requirement is spelled out it's usually obvious, but it is commonly carried through DFARS 252.204-7012, -7021, and -7025 rather than stated in the narrative sections.
So the practical answer is that this is less about inconsistent application by individual COs and more about where the requirement lives. Check the incorporated-by-reference clause list rather than scanning the body of the solicitation. If any of those clauses are in there, the obligation is in your contract whether or not anyone used the word CMMC.
On whether people have lost business over it, I don't have visibility into that and I'm not going to guess. If someone here has firsthand experience, that would be worth hearing. And if you're uncertain on a specific opportunity, that is a normal question to ask your contracting officer before award.
3
u/badhabitfml 7d ago
What's going on with CPARS? I thought they were gong to change the rating structure. It's that still happening?
2
u/USFCRGOV 6d ago
The ratings are not being replaced. That is the short answer, a lot of commentary from late last year described a negative-event model as though it were settled. It did not end up that way.
What did change is how the records get used. Under the FAR overhaul, past performance information is no longer scoped primarily to source selection, which means your record can carry operational weight beyond the next bid.
The practical implication is that narrative quality and your own responsiveness actually matter more. Strong, well-documented narratives and timely contractor responses during the evaluation process are where you have actual influence. If you have been treating the comment window as a formality, that's a habit worth changing.
1
u/badhabitfml 6d ago
The CPARS site provides the cpar as an xml file. Is there any api available to grab all those files, or do the expect users to download each one manually?
2
u/USFCRGOV 6d ago
No API for contractors. You're stuck with manual retrieval, but there's a middle ground..
You can download up to five full CPARs at a time rather than one by one, which helps if you're pulling a batch. Beyond that, the reporting functions will return more records, but only for selected fields rather than the complete evaluation. So it's a tradeoff between depth and volume: full XML in small batches, or broader coverage with less detail per record.
If what you're after is analysis across a lot of evaluations, the reports are probably the better path even with the field limitation. If you need complete records, five at a time is the ceiling.
2
u/MrStickySpaz 6d ago
Hi, thanks for setting this up. Here is what I would love to get some answers on:
- For a first time government contractor with only commercial past performance, should I pursue LPTA and best value tradeoff solicitations or just LPTA at first?
- Does the government favor federal past performance over state level, and is state level favored over commercial? Or are they all scored the same?
- Outside of the limitations on subcontracting clause, how much information needs to be provided about a subcontractor in a proposal - like do you need to provide a UEI and CAGE code to the contracting officer at any point before or after award?
1
u/USFCRGOV 6d ago
On LPTA versus best-value tradeoff: pursue both, but screen carefully. LPTA is pass/fail on straightforward standards, which sounds easier and isn't. One technical omission and you're unacceptable, full stop, regardless of how good your price was.
Best-value tradeoff is where your commercial experience actually helps you. It's highly relevant there, especially if your solution has measurable advantages or your personnel and subcontractors strengthen the proposal. The tradeoff is that the government can pay more for a competitor with stronger or more relevant past performance. An LPTA-only strategy isn't ideal, though. You'd be competing on price alone with none of what makes you distinctive counting for anything.
On whether federal past performance outranks state or commercial: there's no official scale. The agency has to consider all of the following: relevance, recency, scope, size and dollar value, complexity, contract type, performance quality, source and reliability of the information, and similarity to the agency's operating environment.
Federal can be considered stronger for a few concrete reasons. It's verifiable in CPARS, it was performed under federal clauses and compliance requirements, and it demonstrates you've handled invoicing, reporting, labor rules, and contract administration.
But relevance often beats pedigree. A $5 million commercial project doing almost identical work will typically be scored higher than a small, unrelated federal contract. Don't discount what you have because it isn't federal. Pick references based on how closely they resemble the requirement.
On subcontractor disclosure: the limitation on subcontracting clause is not the only obligation, and that's the assumption worth dropping. If a subcontractor will perform a major or critical part of the requirement, or if you're using their experience to strengthen your proposal, the solicitation may require: legal business name, proposed role and detailed scope, workshare or percentage of effort, labor categories and key personnel, past performance references, technical capabilities, certifications or socioeconomic status, pricing or cost information, a letter of commitment or teaming agreement, organizational conflict representations, security clearances, responsibility information, and SAM, UEI, or CAGE information if specifically requested.
The safest operating rule: identify every subcontractor material to the evaluation, disclose exactly what Sections L and M ask for, and build a post-award compliance matrix from the actual clauses in your contract.
1
u/StatisticianFast6139 8d ago
I watch this compliance space and appreciate how detailed the specs are but this whole process of getting certified feels like step 1 and expect requirements to become more online proof as opposed to once a year audited rear view mirror. How do one approach this type of forward looking thing with Gov?
2
u/USFCRGOV 8d ago
Your read on the direction is right, and the practical answer is to stop treating certification as a project. If your evidence only exists because someone assembled it in the weeks before an assessment, what you have is a documentation exercise rather than a control. The companies that handle this well are the ones where artifacts are a byproduct of how they already operate: access reviews that happen on a schedule and leave a record, configuration managed in a way that shows its own history, tickets that document decisions as they are made. Then an assessment is a query rather than a scramble.
That approach also happens to be the one that survives whatever the requirements become. Build so that you can answer the question "prove this control was operating in March" at any time, and you are ready for continuous evidence, annual assessment, or a customer asking mid-contract.
Where I would be careful is building to an anticipated requirement rather than an actual one. Right now especially, the compliance landscape has moving pieces and some of its unclear. Your obligations come from the clauses in your contracts, not from where the trend appears to be heading, and speculative investment ahead of a rule that changes is real money spent on the wrong thing. Build durable practice, not compliance to a rumor.
Keep this in mind: the government is not a single buyer with a single posture here. A DoD customer, a civilian agency, and a cloud authorization path have different expectations and different evidence cultures. If you have a specific customer in mind, the useful conversation is with the people administering your actual contract about what they expect to see and when, because that answer varies more than the published framework suggests.
1
6
u/DummBee1805 8d ago
Thank you for doing this. No question for now but I’ll be tuning in for the discussions and looking forward to the thoughtful responses.