By Katie Helwig, President, Mild Red LLC
November 10, 2025 — AFCEA NOVA Small Business Breakfast Series Mild Red LLC proudly serves as a Gold Sponsor for this series.
The Conversation
The November AFCEA NOVA Small Business Breakfast, featuring Emily Reid, Associate Attorney at PilieroMazza PLLC, and moderated by Anil Chaudhry, Senior Advisor for AI, U.S. Government, offered critical insight into the Federal Acquisition Regulation (FAR) Overhaul and its implications for OASIS+ contractors.
Drawing connections from the discussion—and thought leadership shared by Shauna Weatherly, Steven Koprince, and others across the GovCon ecosystem—here are the key takeaways every small business should note as the FAR modernization unfolds.
FAR Overhaul 101: Understanding “Model” vs. “Class” Deviations
- Model Deviation:
- Draft language issued by the FAR Council to guide agencies in applying new, standardized deviations.
- Part of the Revolutionary FAR Overhaul initiative aimed at simplifying and aligning the FAR with statutory foundations.
- Designed to make acquisition rules more concise, readable, and practical.
- Class Deviation:
- A temporary modification to existing FAR requirements—often used to pilot new processes or remove administrative burden.
- Valid up to four years unless adopted through formal rulemaking.
- Allows agencies flexibility to meet emerging mission needs quickly.
- Timing Matters: Class deviations are expected within 30 days of a model deviation—but current rollout delays are likely tied to the recent government shutdown.
- FAR Council Composition: Representatives from DoD, NASA, GSA, and OMB steer the overhaul.
- Next Milestones:
- Industry comments closed November 3, 2025.
- Formal rulemaking now in motion.
- Draft documentation anticipated by year-end 2025; potential publication to the Federal Register in Spring 2026.
FAR Part 19 — Small Business Program Revisions
- Over 12,000 words removed for clarity and simplification.
- The Rule of Two remains at the master contract level—not at the task-order level.
- Size representations will no longer be required at the task-order level.
OASIS+ Connection:
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- Contractors who organically grow beyond small-business status can still compete under existing OASIS+ small-business awards.
- This ensures continuity for firms aggressively expanding yet maintaining their set-aside access.
- 8(a) Program Adjustments:
- All 8(a) awards must now be competed within a transparent environment.
- Automatic release from 8(a) status if the competition/award remains within another SBA-certified category.
- SBA regulations take precedence over FAR Part 19, but updated SBA guidance is still pending (likely delayed by the shutdown).
- Coordination between SBA and the FAR Council is ongoing.
- New 8(a) Sole Source Thresholds:
- $8.5 million — construction
- $5.5 million — all other contracts
Threshold Increases Effective October 1, 2025
- Micro-Purchase Threshold: $15,000
- Simplified Acquisition Threshold (SAT): $350,000
OASIS+ Connection:
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- OASIS+ Task Orders start at the SAT.
- The minimum order value increases from $250K to $350K, impacting on competitive strategies and BAFO requests under the MAC.
- Contractors should update internal pricing baselines and pipelines accordingly.
Contracting Officer Discretion & Protest Rights
- The revised FAR grants Contracting Officers broader interpretation authority—creating both flexibility and ambiguity.
- Observation: Many COs may lack the experience to fully leverage this discretion, posing risk in interpretation and application.
- Under OASIS+:
- GSA (Civilian Agencies): Protests for task orders under $10 million are limited to cases where the order increases scope, period, or value.
- DoD/NASA/USCG (Title 10): The threshold rises to $25 million.
- Above these thresholds: Full protest rights under FAR 16.505(a)(10) apply.
✅ Key Takeaway: Know your Contracting Officer. Their interpretation and judgment will define success under the new FAR environment.
WOSB Certification Update
- Historically, self-certified WOSBs could be credited toward agency WOSB goals at the subcontract level.
- Moving forward, only SBA-certified WOSBs qualify for both prime and sub credit.
- Action Step: Begin your SBA WOSB certification process now to preserve eligibility and contracting continuity.
The Broader Impact — FAR Overhaul Meets OASIS+
- The FAR Overhaul’s focus on simplification and agility aligns with OASIS+’s flexible, multi-domain structure.
- Both reinforce best-in-class, mission-driven procurement through speed, transparency, and contractor accountability.
- Small businesses positioned on OASIS+ should view these changes not as compliance hurdles—but as opportunities to demonstrate maturity, scalability, and partnership with the acquisition community.
Closing Perspective
“The true ROI of an AFCEA event isn’t just in the policy briefings—it’s in the people you meet, the dots you connect, and the strategic conversations that transform information into insight.” — Katie Helwig, President, Mild Red LLC
About Mild Red LLC
Mild Red LLC is a GovCon growth and marketing consultancy dedicated to helping small and mid-tier government contractors compete and win under Best-in-Class vehicles like OASIS+. Through strategic alignment, compliance expertise, and brand integration, Mild Red helps clients turn past performance into future growth. Tagline: It’s All About Past Performance.
