Comment on FR Doc # 2026-12560
Professional Services CouncilSupportTrade association
Summary: The Professional Services Council (PSC), a trade association representing the government contracting industry, supports the proposed Revolutionary FAR Overhaul (RFO) for its goals of modernizing and streamlining the federal acquisition system. They provide specific recommendations to ensure the final rule preserves competition, protects small business access, and maintains practical flexibility for contractors and government officials.
On behalf of the Professional Services Council (PSC), we are pleased to provide comments on the Federal Acquisition Regulatory Council (FAR Council) proposed rule on “Revolutionary Federal Acquisition Regulation Overhaul Parts 6, 7, 10, 18, 26, 37, and 41” (FAR Case 2026-002), as published in the Federal Register on June 23, 2026, and related provisions and clauses in FAR Part 52. This proposed rule supports implementation of Executive Order (E.O.) 14275, “Restoring Common Sense to Federal Procurement,” which states U.S. policy to “create the most agile, effective, and efficient procurement system possible. Removing undue barriers, such as unnecessary regulations, while simultaneously allowing for the expansion of the national and defense industrial bases is paramount. Accordingly, the FAR should contain only provisions required by statute or essential to sound procurement, and any FAR provisions that do not advance these objectives should be removed.”
As you know, PSC is the leading trade association and voice of the government contracting industry, representing the full range and diversity of the federal services, technology, and solutions sector. PSC’s 400+ member companies provide mission-critical solutions to the federal government and range in size from start-ups to multinational organizations. Together, PSC member companies employ nearly one million American workers and contribute—through commercial and government contracts—roughly $1 trillion annually to the U.S. economy.
The Revolutionary FAR Overhaul (RFO) represents a landmark opportunity to modernize the federal acquisition system by reducing compliance requirements that are not based in statue, providing clarifications where necessary, and empowering federal government officials to exercise sound acquisition judgment in support of agency missions. PSC strongly supports these objectives.
Further, PSC believes the RFO Phase II rulemaking process has been essential to ensuring that a more streamlined, flexible framework leads to administrable and consistent regulatory requirements. FAR Case 2026-002 is particularly significant because it restructures the rules governing competition, acquisition planning, market research, emergency acquisitions, socioeconomic programs, service contracting, and utility services. These provisions shape how agencies identify their needs, engage with industry, evaluate available solutions, and determine which contractors may compete.
PSC supports integrating market research more closely with acquisition planning and providing federal acquisition professionals greater flexibility to pursue effective mission outcomes. At the same time, such streamlining should not create rigid preferences for particular contract vehicles or commercial approaches, reduce meaningful consideration of small businesses and new entrants, or encourage agencies to reshape legitimate requirements merely to fit a preferred procurement channel. PSC urges the FAR Council to preserve the health and vitality of the American industrial base that is critical to mission success; the final rule should preserve robust competition and ensure that agencies evaluate commercial solutions, non-developmental items, purpose-built capabilities, and available contract vehicles based on mission suitability, lifecycle cost, schedule, technical risk, and industrial-base effects.
Based on member company and staff input on the proposed rule, PSC offers the following recommendations to help ensure the final rule is practical, predictable, and consistent with the RFO’s objectives. The FAR Council should:
I.Integrate market research and early industry engagement into acquisition planning
II.Replace the rigid order of priority in FAR 7.201(f)
III.Add express small business and new entrant consideration to FAR 7.201
IV.Establish minimum market research documentation and refresh standards
V.Revise FAR 52.207-7 to avoid intrusive or inflexible subcontracting requirements
VI.Govern the emergency procurement list as guidance, not dynamic regulation
VII.Preserve useful service contracting and utility clarifications
Please see attached PDF for detailed comments and recommendations on each of the topics listed above.