Comment on FR Doc # 2026-12559

Re: FAR Case 2026-001, Docket No. FAR-2026-0001, RIN 9000-AO86 Federal Acquisition Regulation: Revolutionary Federal Acquisition Regulation Overhaul, Parts 1, 2, 4, 33, 39, 40, and 53 I respectfully submit the attached comment for consideration in connection with FAR Case 2026-001. The attachment recommends that FAR Part 40 implementation require Open Security Controls Assessment Language (OSCAL)-compatible, machine-readable flow-down packages for controlled unclassified information (CUI) and National Institute of Standards and Technology Special Publication (NIST SP) 800-171 Revision 3 requirements. Where an agency or prime contractor does not use OSCAL, the attachment recommends that the agency or prime contractor be required to document why the alternative format provides equivalent structure, traceability, interoperability, version control, and supplier usability. This recommendation responds to the downstream burden identified by small business subcontractors when cybersecurity requirements are flowed down through broad clause lists, unstructured contract packages, unclear CUI instructions, duplicative questionnaires, and revised terms that do not identify what changed. The proposed approach would not create a new cybersecurity requirement. It would establish a consistent implementation method so subcontractors can determine what CUI is involved, which system is in scope, which boundary is affected, which requirements apply, which organization-defined parameters apply, what changed, and what evidence is required. Respectfully submitted, Kay Wilson VPM Consulting July 9, 2026