FedSubK Feature: Hate the Game, Not the Players - Know the Roles in Federal Contracting
Updated: May 4, 2024
The Federal procurement process has a lot of pain points and it can be a love-hate relationship doing business in the Federal marketplace. But knowing who is involved in the process from the Government can go a long way in navigating frustration and finding avenues to build relationships that, over time, may provide business opportunities. Each role we’ll discuss sees the acquisition with a unique perspective and often a specific filter. But they all have the same end goal; meeting the agency's mission. Understanding who is involved and they perspective they bring is key to talking about the right things with the right people at the right time.
Let's take a closer look at the main roles involved for the Government.
Requiring Activity
The Requiring Activity is the agency or activity charged with meeting a mission and delivering requirements to the end-user, whether an internal or external Government customer. It is responsible for obtaining funding or developing the program objective memorandum. It may also be the organizational unit that develops the written requirement or Statement of Work (or other format) for services requiring a contract. The Requiring Activity can also be the Funding Activity and/or Procurement Activity when it receives appropriated funds directly for the requirement and/or it has the requisite procurement authority and contracting expertise for the type of contract required. Finally, the Requiring Activity supplies a trained and qualified Contracting Officer's Representative (COR) capable of deciding whether service contract requirements are being performed per the contract.
Funding Activity
This is the agency or activity that receives the funding appropriation that will be used to pay for the products or services being procured. The Funding Activity may be part of the Requiring Activity or Procuring Activity, such as the budget or finance office of an agency/organization.
Procuring Activity (also called Contracting Activity)
This is the agency or activity with expertise and procurement authority that will manage the acquisition of the products and/or services required. The Procuring Activity initiates the Federal contracting process by establishing the acquisition strategy, often in consultation with the Requiring Activity (if it is a separate entity). It develops solicitations, responds to industry questions, and oversees the offer, evaluation, negotiation, and contract award activities. The Procuring Activity may also be the entity that oversees contractor performance through contract closeout. However, contract administration activities may be handed to another activity, like the Defense Contract Management Agency (DCMA), when it is part of the agency’s/organization’s process to do so or required by agency policy.
Senior Procurement Executive
The Senior Procurement Executive (SPE) is the individual appointed per 41 U.S.C. 1702(c) who oversees the management direction of the acquisition system of the executive agency, including implementation of the unique acquisition policies, regulations, and standards of the agency. The SPE initiates acquisition policy rulemaking for the agency and decides the processes and procedures to be used in acquisition planning, contract formation, negotiation, contract administration, and contract closeout. The SPE is typically a member of the Senior Executive Service (SES) and a career Federal civilian.
Head of the Contracting Activity
The Head of the Contracting Activity (HCA) is the official who has overall responsibility for managing the Procuring or Contracting Activity. The SPE may choose to delegate certain responsibilities to the HCA for day-to-day management of acquisition processes and certain approvals, when allowable. The HCA may waive certain contractual requirements under specific circumstances allowed by regulation. These authorities are not usually eligible for further delegation to a lower level.
Contracting Officer
The Contracting Officer (CO) is the person with the authority to enter into (sign), administer, and/or terminate contracts and make related determinations and findings. The term includes certain authorized representatives of the contracting officer acting within the limits of their authority as delegated by the contracting officer such as–
- Administrative contracting officer (ACO) – refers to a contracting officer who administers contracts during performance.
- Termination contracting officer (TCO) – refers to a contracting officer who is settling terminated contracts.
A single contracting officer may handle duties in any or all areas of contract formation, performance, termination, or closeout.
The Department of Defense uses “KO” in short for “Contracting Officer” so as not to confuse contracting officers with the military term Commanding Officer (CO).
Contrary to popular belief, the CO does not work in a vacuum and rarely makes all decisions alone. When I was a CO, we would talk with other COs, our supervisory COs, our Contract Specialists, and the entire team listed in this article to make well-rounded business decisions with buy-in. We called it "Contracting by Committee" because we knew that while we knew the regulations, didn't have all the answers and needed all perspectives.
Contract Specialist
The Contract Specialist (CS) is the person who assists the CO/KO in all aspects of the contracting process by preparation of documents, communications with industry, negotiation of contract prices, selection of terms and conditions, coordination and routing of contract documents, oversight of contractor performance, and contract closeout. The CS cannot enter into (sign) contractual instruments nor verbally obligate the Government. The CS may not make decisions on any contract action (pre or post award) that changes the scope, schedule, price, or terms and conditions. They are often the face to the public on solicitations, communications, and other activities that do not require CO/KO input or approvals.
Contracting Officer’s Representative
The Contracting Officer’s Representative (COR) is an individual designated and authorized in writing by the CO/KO to perform specific technical or administrative functions before and during contract performance. The COR oversees the daily activities of contract performance as the eyes and ears for the CO/KO. The COR cannot enter into (sign) contractual instruments nor verbally obligate the Government. The COR may not make decisions or make commitments that change the scope, schedule, price, or terms and conditions of any contract action. The COR does supply input on the contractor’s performance for use by the CO/KO in required performance evaluations.
Very often the COR is from the Requiring Activity and is a technical subject matter expert or program/project manager responsible for the delivery of products or services to the end user. The COR has likely been involved in the acquisition since its inception and has provided counsel and technical guidance to the CO/KO and possibly participated in the development of evaluation factors and criteria, and source selection activities.
Small Business Specialist
The Small Business Specialist serves as an advisor to the CO/KO and Requiring Activity in the development of the acquisition strategy by encouraging opportunities be available for participation by small business concerns within the various socioeconomic programs. They serve small businesses by providing information on how to do business with the Federal Government and maintain a small business outreach program for the Procuring or Requiring Activity. The Small Business Specialist is responsible for monitoring and maintaining statistical data related to the acquisition process. They also assist small businesses that have issues obtaining payments or are receiving late payments as a prime or sub.
Procurement Center Representative (PCR)
Procurement Center Representatives (PCRs) are employed by the Small Business Administration (SBA) and advocate on behalf of the SBA and small businesses in the acquisition process. PCRs work closely with agency contracting staff on upcoming requirements, review acquisition strategies and solicitations, and inform agencies as to updates to SBA regulations and changes in SBA certification programs. PCRs are also a resource to assist agencies in meeting their small business goals and review subcontracting plans from large businesses for compliance before award. PCRs receive copies of cure or show cause notices of small businesses in their territory that are struggling to meet performance requirements.
Supporting Personnel
Others in the Government team may also be involved in the procurement process such as legal counsel, technical experts, budget analysts, and Government Contractor support personnel. These folks play a necessary supporting role to our key players. They are often the other bodies in the room who may not speak, but hear everything you say, also with their unique perspective. They provide subject matter advice to the procurement official. They are the folks you shake hands with at industry conferences and expos. Making an impression and having a well-honed elevator pitch (2 minutes tops) about your company’s capabilities is important to use when communicating with these roles. They can be the people that remind one of the key players about your company.
Federal Contracting is a team sport. The interplay between government personnel in the roles that play a key part in acquisition and industry is crucial for problem-solving and driving innovation in the government space. As you can see, understanding the roles of key players in government is important in developing productive relationships and talking to the right people about the right things. Finding shared goals through mutual perspectives and appreciating each of these roles in Federal contracting from that view allows you to meet each player in the process where they are, know what they do, and lead them to you as a trusted resource and solution-maker.
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FedSubK Feature: Be Seen! Why Your SBS Profile is So Important
UPDATED November 2025 to incorporate changes from the SBA Dynamic Small Business Search (DSBS) to the new SBA Small Business Search (SBS)
I’ve posted on LinkedIn a lot recently about ways to be seen as a little fish in the big pond that is the Federal marketplace. Every GovCon consultant has a take on the best entry points with agencies. My take is there is only one place small businesses MUST put their best foot forward to be quickly and easily seen by Federal buyers for potential opportunities and influence small business set-asides.
The Small Business Administration (SBA) Small Business Search (SBS) is THE PLACE you must be on your A-game.
The Small Business Search (SBS) is a database in which SBA houses information on the current pool of certificated small businesses. Presently, small businesses that do not have certifications or are self-certified, may also create a profile in this database. The SBS is used by contracting officers, small business specialists, large prime contractors, and other small businesses looking for teaming partners to find small businesses that can help meet Federal requirements and identify businesses that can help the Government (or a prime contractor) meet its small business goals. SBS is one of the first--and often only--sources used in market research by agencies to determine the numbers of small businesses able to provide products or services by North American Industry Classification System (NAICS) code.
You can see why this might be an important place to pay attention to, eh?
Businesses have forgotten about the SBS in the last few years because SAM.gov no longer sends small business registrants directly to SBS at the end of their registration to complete the profile like it used to. I HUGE bummer. Businesses now must wait for their SAM.gov registration to be activated, then they can establish an SBA SBS account, claim their entity record, and fill in their company profile in the SBS system. Federal buyers are looking for detailed information from SBS to use as part of their market research efforts.
SBS isn’t only for market research.
Even more importantly, the SBS shows Federal buyers the status of any pending certification applications for the purpose of determining whether you are eligible to compete for a set-aside action. For example, an Economically Disadvantaged Woman Owned Small Business (EDWOSB) can still submit an offer for an WOSB set-aside even with a pending application for certification showing in the SBS. Contracting Officers often use SBS as a source to confirm the socioeconomic certification status and 8(a) program participation along with SAM.gov.
While MySBA Certifications automatically sends socioeconomic certification status to SAM.gov and updates the requisite reps and certs to reflect the correct socioeconomic status, recently it has taken weeks for that migration to occur. WOSBs and EDWOSBs have reported not seeing their correct socioeconomic status reflected in their SAM entity record.
Businesses should always check their SAM entity record to ensure that the proper status is shown within a reasonable time after receipt of an active certification status; usually within 14 business days. If the record is not accurately reflected, you can contact answerdesk@sba.gov or the SBA socioeconomic program under which your business was certified for assistance. If a Contracting Officer says that your SAM record does not reflect the status claimed, ask the Contracting Officer to check SBS for the more accurate information because of these delays.
So now let’s talk about BEING SEEN in SBS and walk through each part of the registration.
Understanding how to maximize the fields in SBS is how you can make the best possible first impression so that Federal buyers want to learn more about YOU!
The Key Words
Often businesses pluck these from thin air and over-generalized based on what they think the Government wants to see. Key words need to reflect and incorporate aspects of your primary NAICS, secondary NAICS, and what you can provide under those NAICS. If you use key words that don’t reflect your primary NAICS, you’ll leave the Government scratching their head about you. They won’t understand the message you’re sending about your company. Be consistent and specific with key words while tying into your NAICS codes in order to leave the best impression. You have 500 characters -- use them wisely.
The Website
Be sure that you include the URL for any website you have. Make it be more than a landing page. It needs to tell your story. It needs to include information about your company, what you sell, past customers, and products or solutions you provide. And most of all, it must be polished. Scrub your site hard for formatting, typos, grammatical errors, etc. Acquisition personnel using the SBS will often quickly click on the site to see just how polished it is. When it looks good, they get the impression you know your stuff and pay attention to details.
The Capabilities Narrative
This is the written equivalent of your elevator pitch. This section should include all the things you’d include in that two-minute speech. Hit hard on what your company specialized in and its core product or service areas. Show the business’s focus and avoid being all over the map by overpromising on the breadth of work the business performs.
Near the end of the capabilities narrative, list any socioeconomic certifications Why not lead with it? Because that certification is only part of your business, and it alone does not get you interest from the Contracting Officer. End with that information so the Contracting Officer can easily see it in a quick query and get your business into their market research counts.
Lastly, identify any government contract vehicle or GSA Schedule your company may hold. If you can catch their eye that you have an existing GSA Schedule or your business participates in the 8(a) program, you’ll get counted and likely get a look in terms of the Contracting Officer wanting to know more. If they need to meet a socioeconomic goal, they can see quickly. You’re helping the Contracting Officer do their job. They LOVE that! (And made another great first impression!)
SBS now also includes a field to add a link to your online capabilities statement. Use it!
“Extras” You Should Never Skip
Performance History
I cannot say this enough…if you history doing work for any Government or quasi-Government entity at any level -- Federal, State, or Local level -- list them! Don’t play the “they’ll see that when I propose” game. Showing performance history—even if it is minimal or commercial and not Government--helps. How? It proves the viability of the business and the size and types of projects you’ve completed. Those goes a long way to determining eligibility of the business based on performance on same / similar work of a same / similar dollar value (“Rule of Two” stuff – you can read more about that here).
Review Your Profile
Go out to the SBS site and use the filters for your NAICS, business name, geographic location, and business types. Make sure your show up and see how your profile measures up to your competitors. Look at their records and see what they included that you haven’t. Use the good ideas of others, but don’t plagiarize. Contracting Officers will see that and that won’t look good for either of you.
Keep Evolving
Your SBS isn’t something that you can just set and forget either. Make reviewing your profile in SBS something you do when you renew your SAM.gov registration every year. If something major changes in your business focus, NAICS, or socioeconomic status, make associated changes in SBS.
What GovCon doesn't always talk about -- The SBS Influence
When doing market research and trying to determine if an acquisition should be set-aside for small businesses, the Government is not only counting about the numbers of small businesses that claim they can do the work under a NAICS code in SBS. They are analyzing your SBS profile to see if your business could be one of the "... two or more responsible small business concerns that are competitive in terms of fair market prices, quality, and delivery" and they have “…a reasonable expectation of obtaining an offer…” from you. (There’s that pesky “Rule of Two” again.)
In other words, based on what they see, could you submit a proposal likely to win? And how does a Contracting Officer determine that? Simply put... the your answers to everything we just covered.
Completing your profile helps tip the market research scales toward a small businesses set-aside and possibly a specific socioeconomic set-aside. If you're all over the map in your SBS narrative, the Government will not consider you viable eligible contractor towards that “Rule of Two” and could possible choose to go another way with their acquisition strategy, away from a small business set-aside. Or worse, they set it aside but remember your name from the market research as one of the businesses that didn’t make their initial market analysis cut.
Influence where you can! SBS is the place where you have a lot of influence!
Have I convinced you to get out there and create or update your SBS profile yet?
While the system is no longer got the word "Dynamic" in the title, don't forget its meaning. Life is dynamic, business is dynamic, and your SBS profile should still be dynamic, too. Get it completed ASAP. You can’t afford not to.
Remember again, SBS IS WHERE FEDERAL BUYERS GO TO FIND SMALL BUSINESSES and where other small businesses go to find teaming partners and subcontractors.
Get out there, GET NOTICED, BE SEEN, and STAY DYNAMIC!
(former title: FedSubK Feature: Be A Dynamic Small Business!)
Ask for the Meet and Greet. Make the Phone Calls.
I sat in on a session yesterday where another GovCon was talking about watching SAM for opportunities. But if you are doing that, you are going to be too late, unfortunately. Small businesses must start ahead of any opportunity announcement and connect with agency personnel early, before the opportunity is announced in order to be known and help shape future acquisition strategies. It got me thinking about my days as a Branch Chief and Chief of Contracting and the small businesses I know that are still flourishing today.
One particular company stands out. They were a new 8(a) firm that asked for a meet and greet. They had no federal work but showed a level of understanding about our mission that made an impression. While our acquisition strategies were in place already for the end of FY run of award, I told them I'd keep them in mind new projects crossed my desk. Every month, without fail, I would get a call or a quick drop in chat from this 8(a) to say hello and briefly inquiry about any possible upcoming projects. During one of the in-person chats about a year after our first meeting, our chief estimator popped his head in my office quickly to apologize for a few late government estimates. He said he was going crazy with end of FY and lack of staff. The 8(a) took the opportunity and said, "We can help with that." While it wasn't ideally the work the 8(a) was looking for, that simple pivot and flexibility, along with the relationship building done to that point, led to a small 8(a) sole source contract for cost estimating support. It was their first federal contract. That small contract quickly turned into a much larger 8(a) sole source contract for the same work that reached its max capacity 18 months earlier than anticipated. That led to 8(a) contracts for environmental the work the company ideally wanted, then graduation from the 8(a) program, and successfully competing on SB set-asides throughout the region and getting their own (successful) GSA Multiple Award Schedule contract.
Ask for the meet and greet. Make the phone calls. This former CO is here to tell you that acquisition personnel and SB Specialists EXPECT to hear from businesses. Large businesses aren't shy about calling (trust me). They may not be able to tell you much, but the relationship building and continual reminder that you know what they are looking for and can fill a niche--even when it's not your first choice of work--is KEY.
Small businesses must start ahead of any opportunity announcement and connect with agency personnel early, before the opportunity is announced in order to be known and help shape future acquisition strategies.
FedSubK Feature: What is Buying In?
"Buying in". Do you know what that is? Let's illustrate it with a little story...
Once upon a time an agency leader🤴 was looking around at things to make 🌟efficient.🌟 They got the idea that every agency should have the same widgets🔅 their agency had.
The agency leader🤴 called up a widget company👩🔧 and said, "We are interested in your widgets. 🔅What kind of discount can you give us?"
The widget company👩🔧 offers a discount 📉 because they know this agency🤴 not only buys for themselves but may buy for other agencies🫅🤴👸 where a highly trusted widget competitor👨🔧 presently has the work.
The widget company👩🔧 was "buying in" -- offering unrealistic discounts📉 that made the price unrealistically low not only for the current effort but also to influence the purchasing decisions on future buys. Then prices usually up 📈 again over time.
Depending on when "buying in" happens there could also be questions related to compliance with the Competition in Contracting Act (CICA) and possible other violations.
This is why agency announcements that management has made a deal for "$1 a license" and other such management interference is of concern. 🚨 Management plays the numbers game. I'm not saying numbers aren't important, but let's just say... there is a real reason why management typically does not hold contract signature authority. 😬😉
The Government is supposed to keep things fair and do its due diligence. But it's falling for the oldest trick in the book.
Risk, intent, compliance with statutory requirements, misunderstanding of requirements, and comparable market pricing must be evaluated when the Contracting Officer has reason to believe a proposed price is unrealistically low price. But are they?
If a contract isn't in place, there there is still a need to follow appropriate competition rules before a handshake deal. If a contract is already in place, there are things to consider when new discounts appear to be unrealistic including the risk of continued performance, depending on the type of product or service being purchased.
The Government gets a quick win to lock in a low rate, saving some money now. That's called the short game. Government buyers getting blurry-eyed over unbelieveably low prices and don't do the long-term analysis.
But I'll bet you a dollar the company is playing the long game. They are watching and waiting, getting to know your needs and asking loads of questions. "When do you use my widget most?" "Who buys the most widgets?" "When do you typically buy widgets?" And then as fast as they dropped the price, they raise it again on you when you can't afford to make a change -- like at an end of fiscal year. That's how they get locked in and receive perpetual contracts.
BTW...the fairy tale above is a true story. I've had new politicals and new leadership / commanders trot companies into my office saying "Company ABC here says they want to sell us "widgets" at a huge discount compared to what we're paying or others are paying now."
Well...okay then.
As a Contracting Officer, whether I could even begin to entertain that idea depends on several things. It's not an automatic "yes". You could replace "widgets" with just about any product or service and it's probably happened to a Contracting Officer somewhere. Especially as new Administrations come into Government.
The stories in the news that made me think -- "Huh, are they buying in?" are the Axios story "Anthropic wants to sell Claude to the Government for $1". (https://www.axios.com/pro/tech-policy/2025/08/05/ai-anthropic-government-sale-dollar) and FedScoop story "Federal agencies can buy ChatGPT for $1 through GSA deal" (https://fedscoop.com/openai-chatgpt-enterprise-federal-government-gsa-deal-general-services-administration-anthropic/).
My husband (also a retired Contracting Officer) and I look at each other often during the news now and, based on the reported discount or price alone, we know that company is likely "buying in". That's based on our combined 72 years of Fed experience and our Contracting Officer "Spidey sense" from having been around the block a few times. But these deals just the most recent in a series of deals GSA is making with companies since the new Administration came to town. OneGov is the program GSA is, in my former Contracting Officer opinion, using to tout savings under for the press releases. But it may come back later to be a big mistake. I hope I'm wrong.
Program/Project Managers and Contracting Officers AND the competition to these companies...LEARN about it and WATCH for it. It's on the rise.
(And don't get me started on having to argue with new politicals, leadership, and commanders about why I can't terminate a current contract and then turn around and give the same work to another contractor at their unrealistic lower price.🙄😱 That's a topic for another time.)
The practice of "buying in" is becoming more common now. Learn about it and how to spot it.
