What the FAR Overhaul Means for Small Business Contractors | The Upstream Window with David Mullis

The FAR overhaul was sold as 500 fewer pages. The person who reads every rule expects it to land back near 2,000.

The rules that bind you get decided before the proposed rule ever reaches your inbox. Almost no one from industry is in the room when it happens.

Chelsea Roberts sits down with David Mullis, Regulatory Affairs Consultant at Gov Contract Pros LLC, who tracks Federal Register, OIRA, and Unified Regulatory Agenda activity for the small business community. His firm has requested an OIRA 12866 meeting on the Revolutionary FAR Overhaul, and by his account it is the only contracting industry group engaging in that process right now.

They get into what the RFO actually removes and what it quietly adds, including new CUI incident reporting, cybersecurity frameworks, and termination protest timelines. David explains why moving forms and examples into the FAR Companion takes them outside notice and comment, why contracting officers' own liability may pull a more flexible FAR back toward large incumbents, and where commercial-first buying lowers the cybersecurity bar. On CMMC, he walks through a 60-day pause that doesn't reach the November implementation date, why primes may require it regardless, and the planned move to NIST SP 800-171 Revision 3 with its supply chain focus.

The back half is The Upstream Window. David makes the case for the 12866 meeting as 30 unfiltered minutes with White House staff and the FAR Council, explains why the SBA size standards methodology white paper now at OIRA is the part that actually binds, and flags why this will be the first size standard reviewed in a post-Chevron, Loper Bright world.

If you run capture, BD, or a small business with a size standard to protect, the time to engage is before the comment period, not during it.

Timestamps:

00:04:20 Is the RFO actually making the FAR shorter?

00:05:40 What does moving forms and examples into the FAR Companion change for contractors?

00:06:50 Will RFO flexibility actually help small businesses win?

00:11:05 Does the commercial-first push create a security gap?

00:15:18 CMMC is paused. Should companies stop preparing?

00:15:52 What changes when CMMC moves to NIST 800-171 Revision 3?

00:23:05 How can contractors actually influence the RFO before it's final?

00:24:38 Will a government shutdown delay the next round of RFO rules?

00:26:52 Are SBA size standards going up or down?

00:27:30 When is the comment that actually changes your size standard?

00:31:35 What does Loper Bright mean for the next size standards rule?

Resources:

• Follow David Mullis
• Follow Chelsea Roberts

Other resources:

• Gov Contract Pros on LinkedIn: https://www.linkedin.com/company/gov-contract-pros
• Gov Contract Pros Website: https://www.govcontractpros.com

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