Reggie Lations If there is one document that keeps a Contracting Officer (CO) awake at night, it’s the Justification and Approval (J&A). In the Air Force, we preach “Full and Open Competition” as the gold standard, but the mission doesn’t always wait for a 45-day solicitation period. Sometimes, there is only one company that can do the … Read more
FAR Part 4 vs. RFO Part 4: Administrative Matters in the Lifecycle Era In the legacy system, FAR Part 4 (Administrative and Information Matters) was often criticized for being a “junk drawer” of regulations. The Revolutionary FAR Overhaul (RFO) has solved this by ditching the old subpart system in favor of a Phase-Aligned Structure. If … Read more
FAR Part 3 vs. RFO Part 3: From Compliance to Integrity In the legacy FAR, Part 3 (Improper Business Practices and Personal Conflicts of Interest) was a disjointed collection of rules regarding kickbacks, whistles, and “revolving door” restrictions. The Revolutionary FAR Overhaul (RFO) has consolidated these into a centralized Ethics and Procurement Integrity (EPI) framework. … Read more
FAR Part 2 vs. RFO Part 2: Trimming the Fat If FAR Part 1 is the soul of the regulation, FAR Part 2 was the dictionary. However, over the years, Part 2 became a dumping ground for terms that didn’t need a regulatory definition. In the Revolutionary FAR Overhaul (RFO), Part 2 has been gutted … Read more
FAR Part 1 vs. RFO Part 1: The Death of the “Prescriptive” Era In the legacy system, FAR Part 1 established the “Federal Acquisition Regulations System.” Under the Revolutionary FAR Overhaul (RFO), Part 1 has been re-engineered. It is no longer just a roadmap; it is the legal shield for Contracting Officers to exercise Professional … Read more
Understanding the DFARS PGI: The “How-To” of Defense Contracting In the world of Department of Defense (DoD) procurement, the Defense Federal Acquisition Regulation Supplement (DFARS) tells you what you must do. However, the DFARS PGI (Procedures, Guidance, and Information) tells you how to do it. Established to streamline the regulation, the PGI contains non-regulatory material. … Read more
If you are working in Air Force or Defense contracting, you live and die by the fiscal calendar. Among the various constraints we face, few are as critical—or as frequently misunderstood—as the Bona Fide Need Rule. As a Contracting Officer, I have seen more purchase requests rejected in September than any other month, usually because … Read more
In the perfect world of government contracting, every requirement would come with a “check in the mail” for the full amount on day one. But as any Contracting Officer (CO) or Program Manager knows, the fiscal reality of the Department of Defense (DoD) rarely aligns with the perfect world. We often deal with Continuing Resolutions … Read more
If you have ever sat in a Clearance session for a major sole-source acquisition, you know the feeling. You walk into a conference room (or log into a Teams meeting) with your binder or laptop, and facing you is a panel: the Clearance Approval Authority (CAA), Legal, the Policy Chief, and a Pricing Analyst who … Read more
If the Bona Fide Need Rule is the “third rail” of government contracting, the Antideficiency Act (ADA) is the entire power plant exploding. It is the most robust and feared statute in federal fiscal law. As a Contracting Officer, you are the gatekeeper of the Treasury. Your signature obligates the taxpayer. If you sign a … Read more