Gov Contract Pros (GCP) opposes the "Revolutionary FAR Overhaul" (RFO), arguing that the "model deviation" process is an illegitimate, non-statutory rulemaking process that violates the Administrative Procedures Act. They request that the FAR Council rescind the model deviations and the proposed rules, citing concerns over regulatory red tape, lack of public notice, and negative impacts on small businesses.

The Associated General Contractors of America (AGC) supports the Office of Federal Procurement Policy's efforts to streamline the Federal Acquisition Regulation (FAR) but emphasizes the need to preserve construction-specific protections and risk-allocation rules. They specifically request clarifications on definitions, protest processes, and cybersecurity requirements to ensure that streamlining does not increase costs or risks for construction contractors.

Quorara, a software and advisory services provider for federal contractors, supports the proposed governmentwide standard for safeguarding Controlled Unclassified Information (CUI) and its consolidation into FAR Part 40. However, they recommend specific improvements to address implementation issues, including resolving the divergence between NIST SP 800-171 revisions, establishing a tiered phase-in period, defining a diligence standard for CUI compliance attestation, and providing governmentwide defaults for organization-defined parameters.

Redstone Government Consulting, Inc. supports the introduction of new FAR contract clauses regarding Controlled Unclassified Information (CUI). However, they request clarification to exempt consulting, accounting, and legal firms from these requirements when they handle CUI solely in support of a contractor's internal functions.

The Net Effect, LLC, an information consulting firm, supports the goals of the proposed FAR overhaul but argues that the rule needs specific language to prevent prime contractors from shifting compliance burdens onto small and medium business subcontractors. They recommend requiring primes to evaluate the applicability of clauses before flowing them down and to provide specific CUI identifications rather than general statements.

Par-Con, Inc., an SBA-certified 8(a) and EDWOSB construction contractor, opposes the proposed FAR overhaul because its emphasis on competition and ordered preferences for existing contract vehicles structurally excludes 8(a) participants. The company requests specific revisions to preserve the statutory sole-source pathway for small requirements and to ensure timely administration of on-ramps for new participants.

Adams Cloud Cybersecurity LLC, a small business, supports the rule's goals of protecting federal information and harmonizing incident reporting. However, they request specific transition support for small firms, including a crosswalk for NIST 800-171 Rev 3, a single reporting pathway for incidents, and recognition of commercial security capabilities as evidence.

An individual with experience in both the U.S. Government and the aerospace and defense industry supports the proposed Governmentwide framework for Controlled Unclassified Information (CUI) and Standard Form XXX. The commenter argues that while the initiative is constructive, the government must provide clearer definitions of CUI boundaries, scope, and order of precedence to prevent unnecessary costs and compliance burdens for contractors and suppliers.

The commenter argues that the CMMC framework imposes significant financial and bureaucratic burdens on small and large businesses, particularly outside the DC region. They request that federal agencies reduce CMMC Level 2 requirements for government projects and simplify the certification process to lower costs and resource investments.

Chugach Alaska Corporation, an Alaska Native regional corporation, supports the proposed rule's removal of the automatic expiration mechanism but argues it does not go far enough. They advocate for explicitly retaining socioeconomic mandates—such as the Rule of Two and 8(a) authorities—from the sunset review process to ensure investment predictability and request government-to-government consultation with tribes before any such reviews occur.