FedSubK Feature: The End of FY Madness: Things Contracting Officers Want You To Know
Updated: Dec 6, 2024
It's that time of year when I start reflecting on end of FY activities. For decades, I worked 60-70 hour weeks starting right after the July 4th holiday through September 30th. It was a grind and I'm not sure if industry necessarily understands, let alone appreciates, the mountains that get moved so that contracts are awarded by 11:59 pm on that last day, September 30th. (And, yes, I've signed my share of contracts at that very last moment.) I thought this year I'd share all the things I wish industry knew from the insiders perspective on what happens during an end of FY in the Federal contracting offices in every agency across the country.
Purchase Request Cutoff Dates
The purchase request package is the trigger to start an acquisition. It answers the six basic questions a KO (Contracting Officer, remember) needs in order to determine their next course of action:
- What is the scope of the work being procured (e.g., services, supplies, construction, R&D, utilities, etc.)?
- What is the random order of magnitude (ROM) estimate for the entire effort?
- What type of funds are being used (e.g., one-year, two-year, no-year), are they available, and if so, what is the committed amount (i.e., the amount fenced specifically for this contract)?
- What is the duration of the scoped effort?
- When does work need to begin?
Every contracting office sets dates by which requiring activities must have their completed purchase requests submitted in order to guarantee award by September 30th. The dates vary by type of action and dollar value based on the processing time required but generally speaking the customary cut-offs are--
- July 1st for large negotiated contracts,
- August 1st for negotiated task orders, and
- August 15th for all other small dollar actions.
This gives the Chief of Contracting a known workload. If only it were that easy.
A Typical Day in the Life of a Chief of Contracting at the End of FY.
It goes something like this:
- It's July 20th. The Commanding Officer (CO in DoD) has met with a customer agency and they just completed their scoping work on a very large key project for critical recurring services.
- He / She promised the customer in that meeting that we (i.e., my office) will have it awarded by September 30th.
- The project manager tells the Contracting Officer (KO in DoD).
- The KO tells me (Chief).
- I call the CO (Colonel) and say, "Sir, we have a July 1st cutoff for actions of this type and size that require a formal acquisition and are a competitive negotiated acquisition."
- Silence on the phone. We both know how it happened. They are a habitually late customer. It's not the first time and it won't be the last.
- The Commander promises my KO will have a complete purchase request package in a few days.
Tick-tock. Tick-tock. Days and more days go by. It's now August 1st and no purchase request package.
How many times do you think this same scenario happens in the last three months of the fiscal year? A few? A dozen? Try many times a week.
Are you starting to see how Requests for Proposal (RFPs) end up being released with short fuses for offer receipt dates? If not, let's talk about...
Procurement Action Lead Times (PALTs).
The PALT is the time between the initiation of a procurement action and the award of the contract. Most types contract actions have a designated PALT duration within which an award should be made. However, the more time lost early in the PALT by the program office or others in reviews and approvals is less for the Contracting Officer later in the process.
The simplified run down of what a Contracting Officer has to fit within the PALT to get every new contract action on the street, regardless of dollar value, is:
- Receive a complete purchase request package (e.g., estimates, scope, technical specifications, and special instructions) -- the preparation of which may or may not count against the PALT, depending on agency policy.
- Conduct market research.
- Develop an acquisition strategy and possibly a formal written acquisition plan (depending on that ROM estimate and use of existing contracts).
- Prepare bid, quote, or solicitation documents.
- Obtain pre-bid/pre-quote/pre-solicitation approvals and legal sufficiency concurrence.
- Issue a pre-solicitation notice (when required).
- Issue the bid, quote, or solicitation.
PALT also includes the offer/proposal period, answering questions during the solicitation period, review of offers, training and overseeing technical and price evaluation boards, documentation of findings, contract formation, award, unsuccessful offeror letters, debriefings, and even a potential protest.
The minimum PALT for the most simple negotiated new contract is 60 days with half of that being the offer / proposal period.
Then there shorter PALTs for task orders and purchase orders at lower dollar values, and other types of purchases (i.e., Blanket Purchase Agreements (BPA), BPA calls, Basic Ordering Agreements (BOAs)), and no PALT for micropurchases. Those also have their own buying process, though not as involved as a new contract. These types of actions tend to pop up out of the blue even later than contracts because people think that smaller dollars equals fewer headaches. Not so.
Getting Back To Our Scenario...
Eventually the procurement package arrives on August 12th. Now the Contracting Officer has to squeeze their work, a 30-day offer/proposal period, evaluation, and award into less than 60 days. Near impossible.
AND
That same Contracting Officer has multiples of these types of actions on their desk at the same time. One action gets awarded and the celebration is short because another is immediately added to your plate.
All which have to be awarded by 11:59pm on September 30th.
Starting to feel panic setting in? Good, because now you can begin to understand the life of a Contracting Officer and Chief of Contracting at the end of EVERY FISCAL YEAR.
And exceptions to the cutoff dates get made over and over again.
I've had my own staff say, "Can't you push back?" Yes, I can. But as a Chief of Contracting you make exceptions early when risk of untimely award is low. You hold your cards for when leadership tries to force that last minute big contract or two into the pecking order when it is far too late to be successful and risk of no award is greatest. And it always happens.
As a Chief, you watch the workload, push people on status and deadlines weekly, monitor overtime, and watch for employee burnout. Then you shift workload as needed based on skill sets. It's non-stop balancing act taking into account remaining time, staff skills, employee morale, agency mission, and public funds. And it's a grind.
So...Why Do Contracting Officers (COs/KOs) Get A Bad Rap?
Bottom line, here are the facts about COs/KOs and Contract Specialists this time of year.
They hate late RFPs and short offer periods just like you. The scenario above happens constantly through the end of FY. So when a RFP drops late, know that COs/KOs aren't doing it for the fun of it. And they aren't making up their time on your time. It is simply that there isn't enough time and if you want the contract (and they want to award the contract on time) everyone has to make it work somehow.
They are the "Enforcers" of Federal procurement. (And yes, my nickname as a CO/KO was "The Enforcer".) Because of this enforcer role, COs/KOs deal with a lot of people that become rude very quickly when they don't get their way. It gets old really quick. Be the one nice person in their day and they will remember you. Honey, not vinegar.
The "End of FY Email Deluge" is H-E-Double Hockey Sticks. Quarter 4 of any FY is NOT (I repeat, NOT) the time to do a huge marketing push at a CO/KO if you haven't done any work for that agency before and don't have an existing relationship. If you haven't done your marketing by this point in the FY, work on your strategy for Quarter 1 of the next FY. Sure, you can send an email or two and let them know you are there if they need a vendor for a last minute purchase order in your area of expertise, or a micropurchase (read my blog on those small actions that are prevalent at the end of FY). Bad timing and pushiness doesn't start any relationship off well.
Our Lips Are Sealed. This 80's song is the "Go-Go" motto of COs/KOs and Contract Specialists year round but especially during end of FY procurements. Why? Risk of jeopardizing a contract award with no time left to recalibrate. If a CO/KO says they can't give you any info, it applies to everyone calling about that same project. It goes back to the rules (which they don't make and only enforce). And they understand it can be frustrating. It can be for them, too.
Money gets tighter the closer it gets to September 30th. When it comes to budgets and funding, COs/KOs don't control any of it. If you worked long hours on a proposal to get it submitted in a matter of days (or hours) only for project funds to never materialize, you aren't the only one disappointed.
COs/KOs and Contract Specialists are constantly juggling the use of multiple Federal systems and tools. Market research tools, SBA Dynamic Small Business Search (DSBS), contractor portals, eOffer and eMod systems, SAM.gov and its Contract Opportunities, contract writing systems, financial management systems, invoice and payment processing, GSA eBuy, GSA Advantage!, Federal Procurement Data System (FPDS), Contractor Performance Assessment Reporting System (CPARS), and more. And each system has workarounds because systems development doesn't keep up with rulemaking and policy. Sounds sort of backwards, right? It does to them, too.
They are not policy experts, but COs/KOs live and die by it. Read the FAR or any FAR supplement. Now you see my point. Enough said.
The sacrifices are big. Only now, in their 30s, have my daughters told me how much of their childhood I missed as a single mom while climbing the ladder, going to college at night, TDYs to negotiate and oversee contracts, and working 60-70 hour weeks for no less than 25%-30% of the year as a CO/KO and Chief of Contracting. I wish I could get it back. No one can. Contracting jobs age people fast. People get sick from the stress. I know the extremely high level of stress over many years and deploying to Afghanistan for several months in a contingency contracting environment contributed to my own cancer diagnosis at age 42 within two months of my return from overseas. I had no prior family history. This happened as I reached my dream job as a Chief of Contracting. And I worked every day while going through treatments except chemo days and a few days after surgeries. I've seen Contract Specialists, Contracting Officers, and the technical folks that support them take computers to hospitals to work while their kids go through leukemia treatments, come back to work the day after a funeral for a loved one, hold negotiations on the afternoon before their wedding that night. All to get it done. They do superhero things at the end of FY, but they are human.
What I'm Trying to Say is...
Be kind at the end of FY. Thank a CO/KO and Contract Specialist for their time, their hard work, and for their service to the public. They are the stewards of the public's funds and they take that job very seriously.
They will do it all again next year, and the next year, and the next knowing what they know of the workload, obstacles, challenges, and successes. And now you know too.
Signed,
A former superhero that is human, too.
References:
Check out the fedsubk.com/about page for a small sliver of the experience that informed the above.
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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.
