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
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