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:

1. 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.

2. 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.

3. 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.

4. 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.