The Looming Government Shutdown—What Contractors Can Do to Prepare
As the Sept. 30 fiscal year-end approaches, agencies are required to keep updated “lapse plans” and follow Anti-Deficiency Act rules if appropriations falter. That means most non-excepted activities pause, obligations generally stop, and contracting officers may issue stop-work or suspension orders. Guidance from OMB and GAO, plus a practical checklist from Pillsbury, outlines what to do now.
Key Details:
- Know your clauses: Stop-Work (FAR 52.242-15), Suspension (FAR 52.242-14), Government Delay (FAR 52.242-17):
These control how you pause work, ask for extra time, and recover costs (usually not profit).
Action: Get direction in writing from the CO, and keep detailed records to support any equitable adjustment. - Document, segregate, communicate: Pillsbury recommends immediate internal tracking (idle labor, demobilization/remobilization, subcontractor impacts), as well as written communication with your CO to obtain formal direction before stopping/continuing work.
- Understand “excepted” vs. “non-excepted” work: Agencies may continue limited activities (e.g., to protect life/property) per OMB A-11 §124; agency lapse plans show how each bureau applies this.
- Reference docs:
- FAR clauses on Acquisition.gov (the three above).
- OMB A-11 §124 (shutdown guidance).
- Antideficiency Act primers (e.g., GAO) to understand why unfunded work must stop.
Bottom line: Get your shutdown playbook ready: inventory active CLINs and funding, prep cost-segregation, notify subs, and seek written CO direction before taking action.
FAR Overhaul | New FAR Companion Guide
On Sept. 9, 2025, the FAR Council posted Version 1 of the FAR Companion Guide, a non-regulatory buying guide meant to work alongside the rewritten FAR and new “Practitioner Albums” as part of the Strategic Acquisition Guidance framework. Early commentary details scope and coverage.
Key Details:
- What it is: A non-regulatory guide that consolidates practical buying tips removed from the streamlined FAR into usable playbooks (with Albums and Category Guides).
- What’s covered now: Version 1 spans many parts (e.g., 1, 4–6, 8–12, 18, 26, 28–29, 31, 33–36, 38–40, 43, 46, 49–51), with ongoing updates expected.
- Where to find it: The acquisition.gov/far-overhaul hub hosts the Companion Guide, model deviation text, Albums, and rolling announcements.
What it means for industry: Expect agencies to lean on these guides for consistency and speed. Contractors should map proposals/compliance narratives to the Companion and Albums where relevant.
GSA makes 11 Official OASIS+ Choices, 4 Blocks of Apparent Awardees
Sept. 10, 2025 — GSA finalized 11 awards on the unrestricted OASIS+ track (now 711 primes), and named 15 “apparently successful” firms across four small business tracks; notices-to-proceed could begin Sept. 23 with ordering the next day. Size-status challenges and other protests are in play.
Key Details:
- 11 final awards on unrestricted; GSA plans to issue NTPs as early as Sept. 23.
- 15 apparent SB awardees: 7 General SB, 4 SDVOSB, 3 WOSB, 1 HUBZone.
- Totals so far: 2,823 small-business winners competing for task orders; protests pending (e.g., 8(a) matters at GAO/COFC).
Takeaway: Check pool status, validate size representations, and watch protest dockets before investing in teaming or capture for early task orders.
GSA OneGov Agreement with Microsoft Secures Billions in Discounts
Sept. 2, 2025 — GSA’s OneGov deal with Microsoft promises steep discounts across M365, Copilot, Azure, Dynamics 365, and security tools—up to $3.1 billion in first-year savings, including no-cost Copilot for up to 12 months for Microsoft G5 customers. Agencies can opt in through Sept 2026; some discounts last up to 36 months.
Key Details:
- Scope & savings: Blended discounts on SaaS/IaaS and security; $3.1B potential first-year savings.
- Highlights: No-cost M365 Copilot (year 1 for G5), discounted Sentinel/Azure Monitor, Entra ID Governance, Dynamics 365 (no-cost up to one year for eligible workloads).
- Timeline: Opt-in through Sept 2026; some pricing protected up to 36 months.
Why it matters: Expect a surge in demand for AI enablement, migration, and governance. Resellers/MSPs and integrators should align offerings to the OneGov pricebook and licensing mechanics.
GSA Unveils 2 Batches of ‘Apparently Successful’ Polaris Bidders
Sept. 2, 2025 — GSA named 27 SDVOSB and 32 HUBZone firms as apparently successful for Polaris, with WOSB still in source selection and the general SB pool under court protest. Polaris is a 10-year small-business IT vehicle spanning emerging tech (AI, automation, immersive tech, DLT, edge). Size-status challenges are expected.
Key Details:
- 27 SDVOSB + 32 HUBZone lists posted; challenge windows open.
- Status: WOSB is still evaluating; the general SB pool is subject to a pending COFC case.
- Scope: Government-wide IT/Solutions emphasizing modern/emerging technologies.
Action for bidders/teammates: Confirm size, validate JV/mentor-protégé paperwork, and line up agile task-order teams for early sprints.
Pentagon to Officially Implement CMMC Requirements in Contracts by Nov. 10
Sept. 9, 2025 — DoD’s DFARS final rule to implement CMMC 2.0 in contracts is posted for Federal Register publication and becomes effective 60 days after publication (Nov. 10). Contracting officers will check SPRS and cannot award to offerors without the required current CMMC status; limited 180-day conditional status is allowed for Levels 2–3 under POA&Ms. Subcontractor flow-down and proposal UID reporting are included.
Key Details:
- Effective date: Nov. 10, 2025 (60 days after publication).
- Award gating: No award without the current CMMC status in SPRS at the required level.
- Phasing & POA&Ms: 180-day conditional status permitted for Levels 2–3; clause prescriptions phase in over three years.
- Flow-down & admin: Clause updates require UIDs, affirmations, and subcontractor compliance.
Contractor takeaway: If you touch FCI/CUI, treat Level 1/2 prep as an immediate award risk. Validate 800-171 implementation, line up a C3PAO if needed, and ensure SPRS entries/affirmations are current.
