New decisions, rules and guidance a contracting officer should know about, with the line that actually matters. This issue is as it was published on 28 September 2026; later issues carry what has moved since.
22 Sep 2026RulesGSA published a proposed rule on 22 September (GSAR Case 2026-G501, 91 FR 60063) that would move Federal Supply Schedule ordering procedures out of FAR subpart 8.4 and into a new GSAR subpart 538.71, cutting them from over 10,000 words to roughly 2,600; the companion move is already inside RFO FAR Case 2026-003, which rewrites FAR part 8 to send agencies to GSA for the procedures. The proposed text organises order placement as a single ladder by dollar value — at or below the micro-purchase threshold, above it but not above the SAT, and above the SAT — rather than the present split across FAR 8.405-1, 8.405-2 and 8.405-3, and states that FAR parts 5, 6, 14, 15, 16 and 19 do not apply unless otherwise prescribed. It also says ordering activities are not required to determine responsibility at the order or BPA level, or to make a fair-and-reasonable price determination at that level for products and services already priced on the contractor’s FSS contract, and relocates order-level materials requirements out of GSAR clause 552.238-115 into the same subpart. Comments close 22 October 2026.
Nothing here governs the order you place today: FAR 8.405 and its three sections still do, and this is a proposed rule. What it tells you is where schedule buying is headed — into GSA’s supplement, so an ordering activity outside GSA would be working from chapter 5 of title 48 rather than the FAR for its schedule orders, and the FAR 8.405-2 citation in your file templates and order documentation would have no home. Two things are worth reading against your own office’s practice before 22 October: whether you have been requiring evaluation plans, scored quotations or a competitive range on schedule RFQs, which the proposed text says are not required, and whether your reviewers expect an order-level price-reasonableness memo the proposed text would no longer ask for.
GSAR Case 2026-G501, proposed rule, 22 September 2026 →
22 Sep 2026GAO sustainGAO sustained one ground of Battelle Memorial Institute’s protest of a National Science Foundation award to KBR Services under RFP 49100425R0006 for Antarctic science and engineering support services. The solicitation required an offeror using subcontractors or teaming arrangements for major or critical aspects of the work to submit prior experience information on them; KBR identified an affiliated company as a member of its team and supplied the affiliate’s unique entity identifier, and the agency credited KBR with that affiliate’s experience and past performance. GAO held the evaluation unreasonable because the proposal never articulated what resources or services the affiliate would provide in performing this contract, and recommended that NSF reevaluate prior experience and past performance, perform a new tradeoff and selection decision, and reimburse Battelle’s protest costs including attorneys’ fees; the six other grounds, among them cost realism and a proposed key person’s cooling-off period, were denied. Decided 10 September 2026; posted by GAO 22 September 2026.
This is an evaluator’s finding, not a proposal writer’s. Where an offeror leans on a parent, an affiliate or a teammate for experience or past performance, the record has to show what that entity will actually contribute to this contract — personnel, systems, management tools, a defined piece of the work — and your evaluation narrative has to say where in the proposal you found it. A team roster, a shared corporate name and a UEI are what NSF accepted, and it cost the agency a reevaluation, a fresh source selection decision and protest costs. If you are evaluating now and a proposal is thin on this, resolve it before you score rather than after award.
GAO, B-424575, B-424575.2 →
24 Sep 2026PendingSBA extended by 60 days the comment periods on its 20 August 2026 proposed rule setting new size standards for 338 industry groups and industries, and on the 2026 Revised Size Standards Methodology published the same day. The extension was effective on filing, 21 September 2026 — the day the original comment periods were to close — and published in the Federal Register on 24 September 2026. Comments on both documents are now due 20 November 2026.
Current 13 CFR 121.201 governs every representation, size determination and size protest in front of you; a proposed size standard is not a size standard, and no self-certification changes today. The reason to look now is planning. If a requirement you are shaping for award next year falls in one of the 338 industries, the set of firms that will qualify as small at that award may not be the set you are sizing the set-aside against today — so check your NAICS against the proposal, and if a revised number would change the acquisition strategy or the subcontracting goals you are negotiating, the docket is open until 20 November.
SBA, extension of comment periods, 24 September 2026 →
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