Defense Acquisition magazine The FAR Revolutionary Overhaul Bimonthly magazine of Warfighting Acquisition University for senior military personnel, civilians, defense contractors, and defense industry professionals in program management and the acquisition, technology and logistics workforce. Defense Acquisition Magazine January-February 2026 Vol LV | No. 2 | Issue 309
A PUBLICATION OF THE WARFIGHTING ACQUISITION UNIVERSITY MARCH–APRIL 2026 DEFENSE ACQUISITION
Interview With DoW Principal Acquisition Policy Director John M. Tenaglia WarU STEPS UP ON REGULATION TRANSFORMATION THE COMPETITION IN CONTRACTING ACT INTELLECTUAL PROPERTY—A VISION FOR FLEXIBILITY WarU STEPS UP ON REGULATION
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06 The Federal Acquisition Regulation Overhaul Benjamin Tyree Defense Acquisition magazine interviews John Tenaglia, Department of War Princi- pal Director for Pricing, Contracting, and Acquisition Policy. 12 Our University: Enabling the Revolutionary FAR Overhaul Kevin Linden and Renee Butler
The Revolutionary FAR Overhaul, one of the most ambitious acquisition reform efforts in decades, is addressed in nu - merous instructional updates.
16 The Competition in Contracting Act Jennifer Jones
Contrary to many expectations, compe- tition often may ultimately expedite con - tracting and enhance results. 22 Intellectual Property— A Strategic Vision for Flexibility Lisa P. Smith
Sustaining long-lived military systems re- quires early strategic planning, especially for intellectual property and data rights.
28 PSMs, Catalysts to Availability and Performance Andrew Morris
32 AM For Building
and Strengthening Product Support Karla K. O’Connor
Product Support Managers (PSMs) orch- estrate the best possible product support outcomes. These provide at the lowest operations and support costs to deliver effective and affordable product support for the Warfighter.
Additive Manufacturing is becoming ess- ential for a robust Product Support Strat- egy.
36 Navy Sustainment Accountability in
26 MDAP Program Manager Changes 45 2025 Warfighting Acquisition Awards ALSO IN THIS ISSUE
Program Acquisition Randy Pilkerton
Recent Navy review and updates ensure that program managers are incentivized and acount- able.
40 Harnessing the Strategic Power of Cross-Functional Teams E.M. Preisser, Ph.D., D.Sc. A childhood game offers lessons about devel - oping better acquisition teams.
VOL LV A Publication of the U.S. Department of War Under Secretary of War for Acquisition and Sustainment Michael Duffey WARFIGHTING ACQUISITION UNIVERSITY President Bilyana Anderson Chief of Staff Angela Carsten Director, Communications & Public Affairs Christen Goulding Defense Acquisition Editorial Staff Editor-in-Chief Norene L. Johnson DEFENSE ACQUISITION NO. 2, ISSUE 309
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John M. Tenaglia, a member of the Senior Executive Service, is currently the Princi- pal Director for Pricing, Contracting, and Acquisition Policy, Office of the Secretary of War. He is responsible for pricing and contracting policy matters that relate to $470 billion-plus in annual contract obli- gations. Prior to his current assignment, Tenaglia served as Head of the Contracting Activity for the Defense Health Agency. He was interviewed by Defense Acquisition magazine’s managing editor, Benjamin Tyree, on Feb. 20, 2026. Q What is your message to the workforce on how to be creative and flexible in planning and awarding a solicitation under the Revolutionary Federal Acquisition Regulation Overhaul [RFO]? A. The RFO is expected to result in reduced burden on our workforce and reduced burden on industry. So, as DoW acquisition teams are forming their solicitations under the new rule set that we are in the process of issuing now, there are opportunities for all acquisition officials—con - tracting officers, program managers, and other functional disciplines supporting department solicitations alike—to embrace the additional discretion to formulate the busi- ness deal that makes the most sense for their requirement. We started this initiative by reducing the internal burden of compliance requirements embedded in the regulations but not mandated by statutory requirements. In revisit- ing those requirements, we’ve come to realize that, be- cause they’re not based in any statutory mandate, we can offer more discretion for our workforce to employ the full range of techniques and approaches to fulfill our mission requirements. Q How do you see the Services streamlining their sup- plements and policies on the RFO and ensuring that contract specialists and officers are able to be innovative and creative in the new Federal Acquisition Regulation [FAR] model text? A. We do operate in a highly regulated business. And over the years, the federal acquisition system has accumulated a tremendous number of procedural requirements at all levels, including at the FAR level, the Defense FAR Supple- ment [DFARS], and then special additional supplements in each component of the military departments. We have been directed by the President through executive order to reduce the content of these regulations, and that includes the supplements. And so, the same philosophy applies to the component supplements—to take a complete relook at all those issuances and ask the critical questions, “Do we really need that? Is it unnecessarily constraining our
Tenaglia addresses the Senior Acquisition Management Course (ACQ 404) May 12, 2025, at DAU (now the Warfighting Acquisition University). Source: Photo by Michael Bubar-Krukowski This image was cropped to show detail and edited using multiple filters plus dodging and burning techniques.
6 DEFENSE ACQUISITION MAGAZINE | MARCH – APRIL 2026
A CLOSE LOOK AT THE Revolutionary FAR Overhaul
Interview With John M. Tenaglia Department of War Principal Director for Pricing, Contracting, and Acquisition Policy
by BENJAMIN TYREE
MARCH – APRIL 2026 | DEFENSE ACQUISITION MAGAZINE 7
workforce from exercising the full discretion that they have?” In many cases, there’s some administrative utility to having some content in these supplements; but overall, there’s a movement to reduce. It’s all going in one direc- tion. Right now, we’re in a deregulatory mode, and that does include the supplements that the Services have put in place. Q From a technical aspect, what do you consider the most significant changes to come? How much of the future contracting process can be facilitated by artificial intelligence [AI]? A. There is certainly significant opportunity to exploit AI in our procurement processes, not only from an efficiency standpoint but also to enable more creative solutions. One side of AI application is within our own business processes. And an example of that, one of the early forms of AI as I suppose you could say, is how we go about selecting the provisions and clauses that we use in our contracts. We have long used what we call a clause logic service that, through prompts like you have with the AI tools, helps our contracting officers more efficiently decide which clauses are most appropriate for their contracts. As you know, within the department we have a wide range of different contracts, whether for major weapon systems, research and development, construction, and services, and a lot of other domains for which we have re- quirements. As a result, we need different contract clauses. So, in partnership with the DLA [Defense Logistics Agency] Information Operations program office, we’re developing what I would call smarter, logical prompts that will help us more efficiently and expeditiously select those clauses— that’s just one example of how AI will improve the efficiency of our procurement process. We are engaged with CDAO
[Chief Digital and AI Office] and others to champion other use cases for our workforce. The other aspect of AI involves how we go about con- tracting with industry for solutions that are AI-informed. That’s a developing policy area that we’re working on with our stakeholders in CDAO and OMB [Office of Management and Budget]. Our aim is to make sure—as we articulate what requirements can be fulfilled through AI solutions— that we understand where those solutions are coming from, so we have our eyes wide open in terms of how our capabilities are being met. Q How are you tackling this monumental project to overhaul the entire FAR and DFARS at once? A. This is a two-phase process. We have issued the model deviation text for the FAR and the DFARS. That has been a unilateral change to the entire regulation set, both the FAR and the DFARS. The first phase has been all unilateral, and the content of those changes has been all about reducing the content of the FAR and the DFARS—rolling back to what the statute requires and our team’s version of what the new FAR and the DFARS should look like. The most important opportunity we have entering phase two is putting out those same parts of the FAR and the DFARS for public notice and comment. In the coming weeks you will start seeing proposed rules published in the Federal Register through the normal rulemaking pro- cess of notice and comment. We need our workforce and industry engaged in phase two and seek their responses to the proposed rules. Our initial pass was to scale it back as best we could. Generally, there’s never any argument from industry when we’re going to take away compliance requirements, and so we were able to unilaterally remove some things. For example, the criticism we often get with FAR part 12 for commercial item contracting is that, over the years, we have imposed too many additional clauses and burdens on industry. We took this opportunity in the first phase to revisit which clauses we really need to put into FAR part 12 contracts. That’s probably the most noteworthy change that we made in phase one, but there are many more sub- stantive changes that we’re looking to advance in phase two that are all deregulatory. For example, we’re revisiting past performance collection and use. That area is ripe with opportunity, given modern business transactions consid- erations about how to enter the next deal with a firm or make a purchase. In most cases, we’re looking at streamlining and sim- plifying to the extent we can. To implement the executive order on “Restoring Common Sense to Federal Procure- ment,” we’re transforming the system to enable the out- comes we need without imposing all the administrative burden that has been tacked on over the years. But the most significant question for the DoW is, how can we navi - gate the procurement process more efficiently to enable more timely delivery of capability to the Warfighters? En - abling speed is one of the foremost criteria that we’re ap- plying to any of these changes.
8 DEFENSE ACQUISITION MAGAZINE | MARCH – APRIL 2026
Q We’ve spoken about the expected comment oppor- tunity on the current regulatory changes. Is there another phase, a second phase, in DFARS that will come out following this process? And if so, when do you expect that to occur, and what can you tell us about your thinking now on the changes that might be included? A. The FAR provides the overarching framework, and with the DFARS, there’s a cascading effect, not only from an ad - ministrative structure, but also, obviously, the substan- tive content of the FAR. And so, there’s a reason that I and my team held off issuing the DFARS class deviations. We needed to see how the FAR text changed. We’ve aligned the DFARS language to the FAR for that first phase. Similarly, finalizing the FAR rules likely will take place through the remainder of the calendar year, in my estima- tion. Then we can really begin in earnest to make sure that the DFARS class deviations we put out are still consistent with the finalized FAR rule. But more importantly, I would say that will be the opportunity for the defense industry and our own workforce to identify DFARS’ unique changes that we can make, again, in one direction. So that’ll play out subsequently. The Honorable Michael Duffey, Under Secretary of War for Acquisition and Sustainment, recently issued an open letter to industry inviting primarily the contractors that support the DoW to participate in this process. What are their ideas for substantive revisions that we can make to our regulation? Now is the time to do that. We began a campaign of our own here in the DoW, taking in those good ideas as we’re formulating not only the FAR changes but also the DFARS changes. Dr. Kevin Rhodes, ad- ministrator of the OMB [Office of Management and Budget] Office of Federal Procurement Policy, is leading the federal- wide effort, while here at DoW, Kimberly Ziegler and I are leading our team of case managers who are developing and publishing myriad cases at the FAR level in partnership with our NASA and GSA [General Services Administration] FAR Council colleagues. Q What do you see as key requirements or needs in workforce training after completion of the RFO pro- cess? A. We are working closely with the Warfighting Acquisition University—they’ve been with us from the very first day that we embarked on this—and with the Federal Acquisi - tion Institute to make sure that our workforce understands and appreciates the spirit with which we’re making these changes, as I mentioned earlier, more toward empower- ment of our workforce. This is where we’re going to need to point out and highlight particular approaches that were dictated by regulatory language that is no longer there. The fundamental principles for contracting profession- als endure regardless of these changes—along with the fun - damentals of how to be a good contracting officer and what you need to know in terms of principles and concepts to be a successful contracting officer. And we’ll need to prove to ourselves that these principles are, in fact, true.
[T]he most significant question for the DoW is, how can we navigate
the procurement process more efficiently to enable more timely delivery of capability to the Warfighters? Enabling speed is one of the foremost criteria that we’re applying to any of these changes.
Q Now, you mentioned publication in the Federal Reg- ister and the opportunity for public review and com- ment in the near term. Can you elaborate on that likely time frame? A. In the coming weeks, we will be issuing in batches the FAR changes for proposed rule, notice, and comment in the Federal Register . Those batches will be released but staggered over the course of approximately a two-month period. Anyone in the public who wants to comment will have ample opportunity to digest what we put out there and respond within 30 days or so from when we issue the proposed rules. Q Will there be other FAR changes once feedback is received from this implementation? A. One of the things that we have baked in is a kind of a re- curring cycle of revisiting everything within the regulation. Most of the content, particularly for the DFARS, is driven by statutory requirements. Each year in the National Defense Authorization Act [NDAA] we are given additional require- ments that need to flow into our contracts. For example, supply chain risk management, prohibitions of the sources and content, particularly in our weapons systems, have been the theme over the last few years. Therefore, in addi- tion to all the RFO cases, we also have our regular backlog of Fiscal Year 2026 and prior NDAAs that we’re implement- ing and trying to weave in when we can and just prioritiz- ing the cases that need to be executed sooner rather than later. For example, there is a DFARS case on foreign own- ership and control. There is a FAR case on semiconductor prohibitions. We’re working those cases in while we are in the midst of changing everything. So literally everything in both regulations, FAR and the DFARS, is on the table for a revisit. It doesn’t necessarily need to be all or nothing. It could be individual parts of clauses on which we’re particu- larly focused, language that is perhaps where the burden outweighs the benefit for the government, and other op - portunities to streamline what we’re imposing on industry in the clauses.
MARCH – APRIL 2026 | DEFENSE ACQUISITION MAGAZINE 9
The curriculum that we have for our contracting func- tional professionals rides on a standard that we share with industry and tells us the key tasks that a contracting professional needs to master to succeed in either buyer or seller roles. We’re looking closely at version 4.0 of that Contract Management Standard—promulgated by the Na - tional Contract Management Association—to make sure it is consistent with what we’re doing with this RFO, but I do anticipate that most of the focus on our workforce will be to encourage and help them understand the constraints that they formerly had and that now have a little more latitude, and they can exercise greater discretion within the guid- ance we are offering. Q What do other acquisition professionals outside the contracting area, such as systems engineers and government quality assurance representatives, need to generally know about the RFO? A. When people think of the FAR and the DFARS, they usu- ally associate it with the contracting workforce, and that is true for the most part. And it’s associated with the industry, of course, through the clauses that we’re using from the regulation in our contracts. But certainly, the business of acquisition involves the other acquisition disciplines—en - gineers, program managers, logisticians, financial man - agers, and all the other functional disciplines. So, there are requirements in the regulation that apply to the entire system. And if the other functional disciplines see the re- duced burden on industry, that’s where I would expect to see most of their focus. That is what we’re asking contrac- tors to do in their contract clauses. Generally, Parts 1 through 51 of the FAR and the DFARS mainly speak to contracting officials and do not necessar - ily require activities of the other functional disciplines. But we’re embarking on a significant movement, and that’s why the DoW leadership has asked me to keep our acquisition executives—the new program acquisition executives [PAEs] across the various components—informed about what we’re doing. If for nothing else, we need to make sure that they are tracking this spirit of empowerment that we are offering our contracting workforce in allowing them to sup - port the PAEs in ways that make the most sense for their given requirements. Q Have you received feedback on how the RFO is viewed by our commercial acquisition partners? A. Yes. We received roughly 800 or so initial comments in RFO phase one, which is the unilateral issuance through
class deviations. The nature of that does not really afford the opportunity for notice and comment in the way that rulemaking traditionally does. However, we did provide an opportunity to receive inputs that was very helpful in for- mulating the proposed rules that we’re working on and will soon be issued. And so, each of our case managers included consideration of that feedback to help shape what we put in the proposed rules. Next, as we move into the second phase, we’ll traditionally accommodate the consideration of all the public comments about the proposed rules and adjudicate those as we finalize the rules. Q How and when will we know that the FAR overhaul has been successful? And are there pending statutory or other changes on the desk right now that could improve the process? A. That is on our minds as we are digging into this signifi - cant effort. Why are we doing this? What are the fruits of our labor going to be? Establishing a cause-and-effect nexus between the reduction of a particular regulatory requirement and the ability for the DoW to acquire war- fare capability quicker or in a more cost-efficient way will be a very difficult thing to measure. You can look at what we have built up in the regulation over the years as a bit
My primary message is to embrace this opportunity. As Mr. Duffey said in his open letter to industry, we’re at a significant inflection point. And I do anticipate we’ll have additional opportunities to work with the Congress to identify those areas where we can further repeal existing statutory requirements that aren’t necessary.
10 DEFENSE ACQUISITION MAGAZINE | MARCH – APRIL 2026
Tenaglia meets with attendees of the Senior Acquisition Management Course (ACQ 404) May 12, 2025, at DAU (now the Warfighting Acquisition University). Source: Photo by Michael Bubar-Krukowski
of a death-by-a-thousand-cuts type of burden that we’ve imposed, not only on our own workforce but on industry. And so, we’re looking for any opportunities to reduce that. And to the extent we can demonstrate a direct relation- ship between the work that we’re doing and any improve- ments—that will take some time. We’ll need to have these new requirements finalized and applied to live acquisitions so that we can prove to ourselves that we achieved that objective. Mr. Duffey’s open letter to industry made those points—that’s what this is all about—and at least for the DoW, the work we’re doing is centered around delivering capability to the Warfighter in a more timely, cost-effective manner. Q Is there anything else that you would like to discuss, or some particular message you would like to leave to the warfighting acquisition workforce or to our university? A. Well, I appreciate the strong partnership we have with the university. I have been in this role for coming up on six years now and made a concerted effort to stay in touch, at least on a quarterly basis, with that entire faculty, particu- larly the Contract Management faculty. This has allowed us to stay connected with the students who are going through the learning process and affords an opportunity to under - stand whether our policies are effective or not. I truly ap - preciate that partnership. This is a lot for our workforce to take on, to absorb. We really need our educators at the university to help our workforce make sense of what we’re doing. At the FAR level, we are taking every opportunity we have through what you’ll see on the GSA’s acquisition.gov website. Those
changes and the use of the companion guides and the prac- titioner albums are helpful. Within the DoW, we’re going to be looking at the use of the procedures, guidance, and in- formation to ensure we’re scaling that back as appropriate. At the FAR level, what you’re seeing in my estimation is with the practitioner guide, and the companion products we’ve long had are useful guidance for our workforce. I want to encourage our workforce to embrace this opportunity. My primary message is to embrace this opportunity. As Mr. Duffey said in his open letter to industry, we’re at a significant inflection point. And I do anticipate we’ll have additional opportunities to work with the Congress to iden- tify those areas where we can further repeal existing statu- tory requirements that aren’t necessary. If we can make the case that individual requirements from existing statutes can be repealed, we’ll continue to make that through for- mal legislative change proposals that either the depart- ment or the administration offers at the OMB level for all federal contracts. We’re doing that because we recognize the need to additionally alleviate unnecessary burdens. We obviously need to continue to impose the requirements that are required by statutory provisions. This is an ongo- ing process that’s part of the responsibility my staff and I have here in [Office of the Under Secretary of War for] Acquisition and Sustainment, and we’ll continue to look for those opportunities and engage the Congress to scale back what we can. Editor’s Note: We thank Warfighting Acquisition University faculty members Kevin Linden, Dave Pearson, and Jennifer Jones for their help with this interview.
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MARCH – APRIL 2026 | DEFENSE ACQUISITION MAGAZINE 11
OUR UNIVERSITY: Enabling the Revolutionary FAR Overhaul by KEVIN LINDEN and RENEE BUTLER
U.S. Marines with 2nd Battalion, 1st Marine Regiment, 1st Marine Division assigned to Joint Task Force-Southern Border (JTF-SB), load onto a U.S. Army CH-47F Chinook during forward operations center training along the U.S.-Mexico border in the San Diego sector, Calif., March 5, 2026. U.S. Northern Command is working side-by-side with the Department of Homeland Security and the U.S. Customs and Border Protection within narrowly defined authorities to provide unique military capabilities to protect the territorial integrity of the U.S. southern border. Source: Department of War photo by Lance Cpl. Zackery Dear This image was cropped to show detail and edited using multiple filters plus dodging and burning techniques.
“This Revolutionary FAR Overhaul, coupled with our overhaul of the DFARS, will significantly streamline business practices enabling DoW to timely deliver capabilities and lethality for our nation’s Warfighters.” —John M. Tenaglia, Principal Director, Pricing, Contracting, and Acquisition Policy, Office of the Secretary of War
The Revolutionary FAR Overhaul (RFO) is not a routine regulatory up- date. It represents one of the most ambitious acquisition reform efforts in decades—a deliberate effort to streamline the Federal Acquisition Regula- tion (FAR) , coupled with an overhaul of the Defense Federal Acquisition Regulation Supplement (DFARS) ; eliminate unneces- sary procedural burden; restore pro- fessional judgment; and accelerate mission delivery. But reform language alone does not deliver capability. Reform must be translated into understanding, and understanding must translate into ex- ecution. The Warfighting Acquisition University (WarU) has positioned it- self at the center of that translation effort—aligning curriculum, certifi - cation, performance support tools, and real-time engagement forums to ensure that the workforce is prepared to operate confidently within the evolving framework. Although con- tracting professionals still rely on the same core principles, the curriculum changes will emphasize areas where the workforce can make more inde- pendent decisions within our guide- lines, all aimed at better supporting the Warfighter. Start With the Source: Acquisition.gov The authoritative source for up- dates is the official Revolutionary FAR Overhaul (RFO) site. This site serves as the governmentwide repository for reform implementation materials and provides practitioners with the foundational documents needed to understand and apply the changes. Among the most critical resources available are the model deviation texts that provide standardized de- viation language agencies and can adapt to implement reform consis-
tently. The site also includes line-out documents for each FAR part that shows the portions of the regula- tions that are proposed for removal, enabling users to quickly identify high-level changes. To support practical application, the site provides access to the FAR Companion, which offers interpre- tive guidance and context for revised regulatory text, and Practitioner Al- bums, which translate regulatory constructs into practitioner-focused explanations and examples. In addi- tion, the Category Management Buy - ing Guide highlights strategic sourc- ing approaches aligned with reform objectives, and comprehensive Fre- quently Asked Questions (FAQs) ad- dress common implementation ques- tions and areas of uncertainty. Together, these resources estab- lish the baseline understanding of reform intent, structure, and appli- cation. The Department of War (DoW) also posts its specific deviations on its Defense Pricing, Contracting, and Acquisition Policy website. WarU directs practitio- ners first to these official sources to ensure alignment with government- wide implementation guidance be- fore layering structured analytical tools and training support. Supporting the Governmentwide Practitioner Workstream Our faculty members have partici- pated in RFO Practitioner Workstream meetings supporting the FAR Coun- cil-led reform effort, which includes representatives from the General Ser- vices Administration (GSA), Federal Acquisition Institute (FAI), NASA, the Office of Federal Procurement Policy (OFPP), and DoW stakeholders.
But reform language alone does not deliver capability. Reform must be translated into understanding, and understanding must translate into execution. The Warfighting Acquisition University (WarU) has positioned itself at the center of that translation effort— aligning curriculum, certification, performance support tools, and real-time engagement forums to ensure the workforce is prepared to operate confidently within the evolving framework.
Through this engagement, some of our faculty were able to review draft deviation language, identify potential ambiguities, recommend refinements, assist in drafting devia - tion text, and gain early visibility into proposed changes to accelerate cur- riculum and asset updates. Faculty also assisted in develop- ing training to keep the workforce ap- prised of changes to the FAR and how they could incorporate those changes into their current and future acquisi- tions. These events to train and dis- seminate information to the acquisi- tion workforce include: • GSA/FAI FAR Forward Open Office Hours webinars , where presenters walk
MARCH – APRIL 2026 | DEFENSE ACQUISITION MAGAZINE 13
through real-world applications of the Revolutionary FAR Overhaul (RFO) , share insights from recent field conversations, and support peer- to-peer Q&A on emerging acquisi- tion challenges. • FAI/OFPP Office Hours for Supervi - sors/Managers Meeting Registration— via Zoom . • GSA/FAI RFO WS 101—Revolutionary FAR Overhaul (RFO) High Intensity Immersive Training (HIIT) Foundations . These one- day Virtual Instructor-led Training sessions cover the intent of the RFO, guiding principles, acquisi- tion planning, and commercial buying. • GSA/FAI Navigating the FAR Framework online training. This can be ac- cessed to learn the RFO vision, the FAR Framework, and resources available to understand the RFO changes. • The FAR Forward Alliance commu- nity in WarU Cornerstone On-De- mand (CSOD) at Realize Your Potential: Learn. Perform. Succeed. This com- munity connects the acquisition workforce from across the federal government. You must be logged into our virtual campus (CSOD) to access it. • RFO Playlists in CSOD include the following: ◦ The RFO Practitioner Albums Playl- ist includes the change sum- maries, lineouts, accelerat- ors, and more, which are also found on the RFO Acquisition. gov website. ◦ The RFO Training Materials playlist includes official source docu- ments such as the White House
Executive Order: “Restoring Common Sense to Federal Pro- curement,” Office of Manage- ment and Budget Guidance on Overhauling the Federal Acqui- sition Regulations System, and recordings of the FAR Forward Office Hours, among other ma - terial. WarU is updating our learning materials to match phased FAR and DFARS deviations, ensuring curricu- lum and assessments reflect the latest requirements. By synchronizing cur- riculum and assessment updates with phased deviation releases, WarU en- sures that both new entrants and ex- perienced professionals are trained— and tested—against the most current regulatory framework. Curriculum, Learning Assets, and Certification These updates extend to the De- fense Acquisition Workforce Improve- ment Act Contracting Professional Certification program. As discussed in the WarU blog, “How the RFO Will Affect the Contracting (CON) Professional Certifica- tion Program,” training materials and certification examinations are being evaluated and revised to reflect the principles-based approach embed- ded in the RFO. RFO comparison tool. To translate reform into practical understanding, WarU developed the RFO Comparison Tool—providing concise summaries of key changes introduced by the RFO across all FAR parts for the acquisition workforce. Each FAR part includes a standardized high-level overview, subpart crosswalk, side-by-side com-
parison tables, companion resource insights, and FAQs. The tool’s design features listed below reflect how practitioners work: • Each FAR and DFARS part/section is organized in an intuitive accor- dion-type format, with its own tab. • Standardized overviews highlight the most important updates—such as clearer language, greater con- tract flexibility, streamlined proce - dures, and enhanced approaches to vendor competition. • Current and revised regulations are displayed in side-by-side comparisons. • Subpart crosswalks maintain con- tinuity with the prior FAR structure. • Companion resource insights are drawn from related guidance. • FAQs address and answer common practitioner concerns. This consistent, accessible format helps acquisition professionals find the information they need quickly and in a way that supports decision-mak- ing rather than regulatory parsing. For DFARS deviations, the RFO Comparison Tool provides similarly structured summaries that include high-level overview, detailed com- parison tables, and DFARS PGI (Pro- cedures, Guidance, and Information) comparisons linking regulatory and procedural guidance, impact state- ments, and FAQs. While DFARS analyses do not in- clude Practitioner Albums or FAR Companion summaries, the inclu- sion of the PGI comparison ensures that regulatory changes are viewed alongside the procedural context practitioners must consider. The platform also integrates a cu- rated CONNECT Live! RFO playlist, links to official resources, and the RFO Quick Review Challenge —featuring more than 60 targeted questions de- signed to reinforce understanding of the most significant regulatory shifts. The Challenge is a focused, part-by- part overview designed to help users quickly grasp the most significant shifts brought about by the RFO. While not intended as a comprehen-
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Reform Requires Readiness The Revolutionary FAR Over- haul seeks to accelerate acquisition outcomes and restore professional discretion. Its success depends not merely on revised text, but on a workforce prepared to apply reform effectively. Through curriculum moderniza- tion, certification alignment, struc- tured analytical tools, collaborative engagement forums, centralized re- sources, and direct participation in the practitioner workstream, WarU is helping translate regulatory reform into operational capability. Reform establishes the framework. Workforce readiness determines its impact. About WarU WarU is the DoW’s premier insti- tution for acquisition education and workforce readiness. It delivers com- petency-based learning, performance support tools, and real-time engage- ment forums that strengthen profes- sional capability across the warfight - ing acquisition enterprise.
sive deep dive, this tool presents a cu- rated selection of over 60 questions in an easy-to-review format, highlight- ing key shifts in the FAR landscape. The RFO Comparison Tool is de- signed not simply to inform, but to enable confident application of re- form in everyday acquisition activi- ties. CONNECT Live! Collaborative dia- logue. To support phased deviation implementation, WarU leveraged CONNECT Live!—an interactive forum where contracting professionals en- gage with subject matter experts and peers across the DoW. Participants analyze newly issued FAR and DFARS deviations, discuss operational impli- cations, share best practices, and ask candid implementation questions. Although Connect Live sessions are usually not recorded, RFO-specific sessions were recorded and added to our curated playlist on the RFO Com- parison Tool page so workforce mem- bers who missed them can still access the information. Current CONNECT Live! Sessions (although again, not recorded) feature extensive discus- sion on the RFO. You can tune in every Thursday at 11:30 a.m. at CONNECT Live! to participate in this dialogue. Coming Next Beyond phased deviations, for- mal rulemaking will further codify changes. Legislative proposals may introduce additional statutory ad- justments. Department and agency supplements—including the DFARS and DoW Component-level regula- tions—must be revised to align with the streamlined FAR structure. WarU remains positioned to support this continued evolution through ongoing curriculum up- dates, certification alignment, an- alytical tool enhancements, and enterprise engagement. To read more, visit the WarU RFO Website. This site provides infor- mation such as background infor- mation, announcements, and ar- ticles. It’s your one-stop shop for RFO-related information!
LINDEN is the center director for Contract- ing and Small Business in WarU’s Require- ments and Curriculum Development Direct- orate. Linden has a 30-year contracting car- eer, first with the Navy and then with the U.S. Treasury Department and the Peace Corps. Linden holds a B.S. degree in Accounting and an M.S. degree in Taxation from Widener University. BUTLER recently retired as the Learning Direc- tor for Contract Price, Cost, and Finance at WarU’s Midwest Campus, Kettering, Ohio. She has 36 years’ contracting experience, 15 of which included active-duty Air Force assign- ments as a Warranted Procuring Contract- ing Officer; Squadron Commander; Air Force Materiel Command Chief of Pricing, Finance and Specialized Policy; and Air Force/U.S. Space Command Staff Officer and Instruc- tor of Cost and Price Analysis at the Air Force Institute of Technology. Butler holds a DBA in Finance from Walden University, a B.B.A. in Management from Ohio University, and an M.S. in Management from Troy University. She holds Level I and Level III certifications in Program Management and Contract- ing, respectively, and a certificate in Proj- ect Management. Author(s) can be contacted at Kevin.Linden@waru.edu . The views expressed in this article are those of the authors alone and not the Department of War. Reproduction or reposting of articles from Defense Acquisition magazine should credit the authors and the magazine.
Related Resources
– (CON 3910) Online Contracting Certification Exam Prep (Online Training Course) – (RFO WS 101) Revolutionary FAR Overhaul (RFO) High Intensity Immersive Training (HIIT): Foundations (Virtual Instructor Led Training) – Revolutionary
– How the RFO Will Affect the Contracting (CON) Professional Certification Program (Article) – Revolutionary FAR Overhaul (“Contracting Conversations” Podcast) – Revolutionary FAR Overhaul (Comparison Tool) – RFO Quick Review Challenge (60-Question Review Tool)
FAR Overhaul (News Articles) – Revolutionary
FAR Overhaul Aims to Streamline Acquisition (Article)
MARCH – APRIL 2026 | DEFENSE ACQUISITION MAGAZINE 15
The Competition in CONTRACTING ACT by JENNIFER JONES
Eleventh in a series of introductory articles on contracting. When attending contracting certification courses, students often are asked to perform exercises that relate to contract- ing issues they may not understand. They can do the exercises following the processes we teach them, but the best students want to know what it all means. Their inquiries inspired me to write this series of articles.
U.S. forces participate in a live fire involving Patriot missile launches during exercise Sky Shield at the Udari Range Complex, Kuwait, Dec. 9, 2025. Led by Kuwait, exercise Sky Shield included participation from the United States, Bahrain, and the United Kingdom. Source: U.S. Central Command Public Affairs
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As with most articles in this series, it is important to put the topic of competitive procedures under discussion within the context of the mission of the Department of War (DoW). How will this impact readiness? In my experience, some customers opine that the use of competitive procedures delays the process and may result in inferior products or services (when compared to their preferred source). However, in the bigger scheme, competi- tion more often has the exact opposite result.
When the government solicits and obtains competition, it can result in monetary savings, innovative solu- tions, expansion of the industrial base, increased transparency and confidence in the procurement pro - cess, and expanded opportunities for various businesses, often without considerable added lead time to con- tract award. And expanding the De- fense Industrial Base is a key goal of the department’s Acquisition Trans-
formation Strategy. Competition is a vital component of this strategy. Historical Context The Competition in Contracting Act of 1984 (CICA) created major changes in the requirements for competition for the federal government and the (then) DoD. Prior to 1984, the Armed Ser - vices Procurement Act of 1947 estab - lished our competition requirements. This was implemented in the Defense
Table 1. Exceptions To Formal Advertising Requirement
The following are the 17 exceptions to the requirement to use Formal Advertising under the Armed Services Procurement Act and Defense Acquisition Regulation. The ones in bold are now exceptions to full and open competition under CICA. y National emergency y Public exigency (e.g., unusual and compelling urgency) y When only one source is available y When authorized by statute y When the contract is for personal or professional services y When the contract is for educational or research institutions y When the contract is for technical equipment requiring standardization y When the contract is for experimental, developmental, or research work y When the contract is for utility services (Only one source includes this possibility) y When the contract is for supplies purchased in foreign countries y When the contract is for perishable subsistence supplies y When the contract is for brand-name items for resale (authorized by statute) y When the contract is for services by nonprofit organizations (authorized by statute) y When the contract is for services by blind or disabled persons (authorized by statute) y When the contract is for printing and binding (authorized by statute) y When the contract is for transportation services y When the contract is for contracts with foreign governments or international organizations
Source: Adapted by author from listed sources
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scribed as a contracting environment, in which “all responsible sources are permitted to submit bids, quotes or proposals.” To maximize competi- tion, we publicize proposed contract actions to ensure that all responsible sources are aware of the requirement and can submit offers. Full and Open Competition After Exclusion of Sources FAR subpart 6.2/RFO FAR 6.102 dis - cuss the second category of competi- tion, FAOC after exclusion of sources. Many of these are based on statutory exceptions to FAOC. As you might ex- pect, in these cases we will exclude certain companies or categories of companies but obtain FAOC among those not excluded. Examples of groups that may be excluded include large businesses (resulting in FAOC among small businesses) or nonlocal firms during a natural disaster (result - ing in FAOC among local businesses). We may also perform FAOC after exclusion of sources to limit com- petition to various socioeconomic categories such as service-disabled veteran-owned small businesses (SDVOSBs), women-owned small business (WOSB), etc. As you might suspect, once we exclude everyone except SDVOSBs, we would solicit FAOC among the SDVOSBs. None of the above actions requires additional documentation or approval as they are specifically authorized by statute. The final category within this level of competition is to establish or maintain alternative sources. For example, perhaps one manufacturer always wins contracts for tanks. We do not want it to be the only com- pany able to provide them. We need to grow the industrial base. So, we would execute a Determination and Find- ings to exclude that company from a particular competition, allowing all other responsible tank manufactur- ers to compete fully. The RFO DFARS Procedures, Guidance, and Informa- tion (PGI) 206.102-1(b)) even includes a sample Determination and Findings document. While this might be more
In my experience, some customers opine that the use of competitive procedures delays the process and may result in
inferior products or services (when compared to their preferred source). However, in the bigger scheme, competition more often has the exact opposite result.
3. Other than FAOC . FAR subpart 6.3/ RFO FAR 6.103 We will discuss each in turn. Of note, RFO FAR 6.001(a), FAR part 6 does not apply to contracts awarded using simplified acquisition proce- dures. But FAR 13.104 has its own re - quirements for maximum practicable competition. This is different from FAOC; processes and approvals are different for actions under the sim - plified acquisition threshold. Full and Open Competition FAOC is not specifically defined in FAR parts 2 or 6, although com- petition is discussed throughout the FAR, especially in FAR parts 6 and 15. However, FAR 6.102 /RFO FAR 6.101 do identify procedures that provide for FAOC. These are the use of sealed bids (which may be used only when multiple offers are expected—hence requiring competition), and competi- tive proposals, a combination of pro- cedures or special procedures used in specific cases. Examples would in - clude use of broad agency announce- ments when contracting for research and development, use of Federal Sup- ply Schedules, etc. These special situ- ations are beyond the scope of this article. The concept of FAOC is also closely aligned with the concept of publiciz- ing contract actions as discussed in FAR part 5 . Publicly posting proposed contract actions enhances competi- tion and opportunities for small busi- nesses. This will be a topic for a future article. But, in brief, FAOC can be de-
Acquisition Regulation, the predeces- sor to the Federal Acquisition Regula- tion (FAR) and DoD FAR Supplement (DFARS) prior to 1984. Pre-CICA, requirements for com- petition were less stringent. In fact, the emphasis was on the procure- ment method. We were required to use formal advertising (now known as sealed bidding) rather than con- tracting by negotiation unless we met and documented one of 17 ex - ceptions such as national security, perishable subsistence, etc. (Table 1). The very nature of formal adver - tising ensured transparency and was founded on an assumption that com- petition was a given. This all changed with the advent of CICA and publica- tion of the FAR . CICA (and the FAR) be- came effective in 1984 and required “each executive agency to allow and encourage the maximum number of sources to submit sealed bids or competitive proposals before enter- ing into any contract for the procure- ment of property or services.” (Note the addition of competitive proposals as a desired methodology.) It also dif- ferentiated “requirements for use of limited competition and noncompeti- tive practices in procurement.” Under CICA, three levels of com- petition are now discussed in the FAR part 6, Competition Requirements . 1. Full and open competition (FAOC) . FAR subpart 6.1/RFO, FAR 6.101 2. FAOC after exclusion of sources . FAR subpart 6.2/RFO FAR 6.102
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