On January 14, the Coalition for Common Sense in Government Procurement (the “Coalition”) held its Winter Training Conference (formerly known as the Fall Training Conference during non-shutdown times). The General Services Administration (“GSA”) leadership stole the show headlining a number of panels focused on topics that likely are top of mind for Schedule contractors. Below, we provide key highlights of what we found to be most notable—including the Federal Acquisition Regulations (“FAR”) overhaul, GSA’s consolidation action plan, and the GSA-wide transition to transactional data reporting (“TDR”)—along with our thoughts on what it all means.
The Big Picture
Many of the changes happening at GSA right now are related to various Trump Administration Executive Orders. By one panelist’s count, there are 57 Executive Orders affecting the agency. We’ll take GSA at their word. At a high level, these are the “7 Big Things” GSA is trying to implement consistent with these Executive Orders:
- Reducing prices and administrative costs to the Government (in large part through a smaller, more nimble regulatory regime). (Yes, we do think that’s coded speak for the Revolutionary FAR Overhaul.)
- An emphasis on taking action—the new attitude is to move fast and break things—consistent with the Trump Administration’s approach to a number of priority projects.
- Eliminating duplication, which will be achieved through consolidating procurement vehicles.
- Buying commercial products and services. (It should surprise no one that this is a focus of GSA, the owner of the largest commercial products and services contract vehicle known to mankind.)
- Encouraging fixed price contracts (which reduce the risk to the government).
- Reiterating the importance of competition and encouraging participation by innovative new entrants.
- Reducing bid protests by emphasizing and encouraging protests to the agency (with resolution in 30 days). (We’ll decline to use this as an opportunity to get on our soapbox on the limited utility of agency-level protests.)
We expect to see additional movement on each of these fronts throughout 2026.
The Revolutionary FAR Overhaul
The overhaul of the FAR has certainly been top of mind for us (and in case you forgot, our Revolutionary FAR Overhaul Tracker continues to track these changes). As a reminder, Executive Order 14275, Restoring Common Sense to Federal Procurement, directed the FAR to be streamlined by removing non-statutory text and burdensome requirements. The Office of Federal Procurement Policy (“OFPP”) and the Federal Acquisition Regulatory Council (“FAR Council”) are spearheading the effort to overhaul the FAR, consistent with the EO’s directive. At the end of FY 2025 (i.e., Sept. 30, 2025), the FAR Council completed its draft rewrite of all FAR Parts. All revised FAR Parts were then implemented via agency deviations.
Luckily, the Winter Conference gave us a glimpse into what’s next (literally, one of the sessions was called, “The Revolutionary FAR Overhaul—What’s Next?”). Here’s what we learned.
By the end of January 2026, all agency deviations should be in place. This will mark the official end of “Phase 1,” during which the FAR Council drafted model deviations and those deviations were unilaterally adopted via agency deviations. The agency deviations allow the new FAR language to have immediate effect while rulemaking proceeds.
Beginning in April 2026, the FAR Council will begin to release Proposed Rules on a rolling basis. This means we will see batches of rules being released rather than one massive rule to revise the entire FAR. Two points about the Proposed Rules. First, the Proposed Rules will not match the language in the model deviations. The FAR Council received over 2,000 comments following release of the model deviations and has been busy having “robust discussions” with industry since then. The language in the Proposed Rules will reflect those comments and discussions. Second, the fact that these revisions are being released as Proposed Rules (rather than Interim Rules) means they will not have immediate effect. As such, contractors will continue to follow the language in applicable agency deviations until the Final Rules are published. Additionally, there will be an opportunity for industry to submit comments on the Proposed Rules. Those comments will inform the Final Rules.
Speaking of Final Rules, the FAR Council is aiming to have all rulemaking completed by the end of this fiscal year, though one panelist acknowledged this likely will slide back a bit because the government shutdown slowed things down. The panelists did note (several times) that this timeline is aggressive, and we would not be surprised if it gets delayed a bit.
At some point, presumably after the Final Rules are issued and the FAR officially is updated, we expect to see similar changes to the General Services Administration Regulation (“GSAR”), Defense Federal Acquisition Regulation Supplement (“DFARS”), and NASA regulation supplement. The NASA representative on one panel said the NASA revisions will be implemented one year from when the FAR revisions are final (i.e., end of FY 2027).
One panelist noted a major challenge to the FAR overhaul is community readiness. Given the speed at which the overhaul is occurring (i.e., 5 months to complete the initial rewrite, and one month to socialize it during a government shutdown), education on all sides will be critically important. Both the government and industry need to understand the changes for the changes to be effective. To that end, the government will be offering some training sessions, and the non-regulatory resources (e.g., the FAR Companion, the Category Management Buying Guides, and the Practitioner albums) will serve as primary tools to strengthen critical thinking, increase market awareness, and assist with risk literacy.
GSA’s Consolidation Efforts in Response to Executive Order 14240
The next area of focus covered GSA’s consolidation efforts to streamline the procurement processes for common goods and services purchased by federal agencies through GSA. These efforts stem from Executive Order 14240, Eliminating Waste and Saving Taxpayer Dollars by Consolidating Procurement, released in March 2025, which aims to (1) simplify procurement processes government-wide; (2) eliminate waste and duplication; and (3) enable agencies to focus on their core missions.
The EO calls on GSA to manage an efficient and effective procurement system for agencies in the interest of American taxpayers and “return the [GSA] to its original purpose, rather than continuing to have multiple agencies and agency subcomponents separately carry out these same functions in an uncoordinated and less economical fashion.” In accordance with the Executive Order, GSA outlined its implementation plan in Office of Management and Budget (“OMB”) Memo M-21-31, Consolidating Federal Procurement Activities and the GSA panel at the conference provided several key updates on its progress, discussed further below.
1. Office of Centralized Acquisition Services
GSA established the Office of Centralized Acquisition Services (“OCAS”) to serve as a singular enterprise-wide acquisition model and to partner with federal agencies to provide direct contracting support for common goods and services (such as laptops, office furnishings, etc.). OCAS is currently structured as an opt-in model for agencies to benefit from centralized, streamlined, and discounted purchasing procedures. The panel likened OCAS’s role as the “Contracting Officer” and the Agencies as the “Contracting Officer’s Representative” for such common government purchases. To date, OCAS is currently managing over 1,000 contracts worth over $1.5 billion in federal spending and plans to focus efforts on engaging with agency customers and responding to requests for OCAS’s procurement assistance.
2. Category Management & Shared Services
GSA’s category management approach helps agencies purchase products, services, and solutions like an enterprise by identifying core spend areas and using data to consolidate agency contracts, resulting in greater savings and value. The approach is laid out in a 2019 OMB Memorandum, M-19-13 Category Management: Making Smarter Use of Common Contract Solutions and Practices, which mandates that agencies develop vendor management strategies and establish plans to share data across the government (among other steps), all in an effort to “bring spending under management and leverage common contract solutions and practices.” The panel explained that GSA was not previously looking at agency requirements through the lens of categories and had no visibility into common spend areas. By focusing on category management, GSA is able to generate data to inform common spend areas that are ripe for consolidation.
In a similar effort, GSA also discussed its shared services portfolio that brings together commonly needed agency functions like acquisition, data and analytics, and financial management into a centralized location. To promote Government-wide shared services, GSA is to identify common agency needs and improve the availability of commonly needed goods and services to enable the agency to focus on its respective mission. As part of the shared services portfolio, the panel highlighted the City Pair Program, which provides pre-negotiated discounted air passenger transportation services for federal government travelers in a centralized location, and GSA’s Fleet Services, to manage federal vehicle purchasing and leasing (again, in one convenient location—a common theme).
3. OneGov Strategy
The topic that created the most stir (in our opinion) was the panel discussion on GSA’s OneGov strategy, a phased approach—starting with Original Equipment Manufacturers (“OEM”) software—that establishes standardized terms and pricing to streamline access to software and IT tools.
This initiative kicked off in Spring 2025 with GSA’s IT Vendor Management Office (“ITVMO”) looking into how the government was acquiring and managing Microsoft products in particular (one of the largest OEMs for the government). The ITVMO analyzed the entire acquisition process across the government for ways to consolidate and compiled data establishing pain points and best practices to reduce friction in the acquisition and management process. This data was used to inform and feed into the OneGov strategy. Similar to GSA’s category management efforts, the goal of OneGov is to order like an enterprise. According to the panel, OneGov currently has about 20 agreements in place with OEMs, resulting in more than $500 million in savings so far. As mentioned, OneGov efforts are currently focused on enterprise-wide software and will use data to inform what this strategy could look like for other segments of the federal commodity space.
Questions raised by the audience flagged potential shifts for software resellers given the GSA’s move to purchasing software licenses directly from OEMs. When asked how resellers now fit into the equation, the GSA panel encouraged software resellers to communicate with OEMs to assess whether the OEM will be participating in OneGov and if so, how to re-structure agreements so that privity of contract exists between the GSA and the OEM (instead of the service providers) and service providers are managed by the OEM (similar to a prime and subcontractor relationship). The panel emphasized that OneGov is an entirely voluntary program and that if the OneGov strategy does not make sense for certain OEM’s, there is no requirement to participate.
While OneGov’s true impact on software resellers is a bit unclear right now, we agree with GSA’s advice for resellers to keep the dialogue open with OEMs. As we understand GSA’s approach, OneGov will likely not apply to the entire IT ecosystem and appears to be less focused on service-based offerings. In addition to keeping open communication with OEMs, resellers should consider reaching out to GSA directly to discuss potential business impacts and keep an eye on GSA’s OneGov website for any announcements or requests for industry participation.
Transactional Data Reporting Rule Expansion
As a primer, TDR is GSA’s way of aggregating data on the prices paid for goods and services through the Schedule to better understand what the government is buying and for how much and to inform GSA’s future decisions on consolidation.
To industry’s surprise, GSA is making anonymized TDR data publicly available through its Data to Decisions (“D2D”) platform. The GSA’s D2D platform marks an innovative step in government procurement transparency, offering contractors never-before-seen insights into federal buying patterns. By uploading anonymized and aggregated order-level data, GSA allows users to see precisely which agencies are purchasing which items and at what prices. This rich data set provides both GSA and Schedule contractors critical business intelligence that can help identify market opportunities, understand competitive pricing, and make strategic decisions.
Currently, GSA’s stated focus with the D2D data is to empower government ordering agencies to negotiate better deals at the transaction level—not to drive down GSA list prices. Over time, however, our expectation is that GSA will use the order-level pricing trends to inform broader price negotiations.
The fun doesn’t end there—GSA specifically touted the D2D platform’s utility in driving contract compliance. For example, one GSA panelist presented a hypothetical of a non-Trade Agreements Act (“TAA”) compliant product sale. If GSA identifies a non-TAA-compliant product, it can trace all related sales through the Schedules program and quickly notify impacted agencies (and, in turn, take any necessary action with respect to the contractors that sold the non-TAA-compliant products).
GSA did acknowledge challenges faced to date with respect to TDR data reporting, and specifically with respect to TDR data for services and highly customizable products (categories that account for more than 80% of Schedule sales). Although GSA is committed to maximizing data usability, contractors should be prepared to advocate for their interests if GSA attempts to use TDR information to reduce prices in situations where direct comparison is difficult.
Finally, the aggregation of pricing data supports category management objectives (as we discussed above) and benchmarking efforts. GSA will be better positioned to compare ceiling rates versus actual prices paid and develop more accurate cost estimates. For contractors and agencies alike, these insights facilitate more informed negotiations, helping ensure labor rates remain sufficient for nationwide service delivery while driving realistic pricing and value for the taxpayer.
Conclusion
From the ambitious, dare we say revolutionary, FAR overhaul and GSA’s consolidation strategy, to the expanding role of transactional data in driving smarter purchasing and compliance, the themes of modernization, efficiency, and data-driven decision-making were front and center of the conference. As federal contractors navigate this rapidly evolving landscape, staying involved and informed will be essential to success, particularly where implementation timelines are shifting and uncertainties remain. The conference made clear that GSA’s commitment is to reforming procurement in ways that promote transparency and innovation, ultimately delivering greater value to the taxpayer. We will continue to monitor developments (including at the Coalition’s May “Spring” Training Conference) as these initiatives move from policy into practice.