What the FAR Overhaul Means for Small Business Contractors | The Upstream Window with David Mullis

What does the FAR overhaul actually mean for small business contractors? The Revolutionary FAR Overhaul was sold as cutting the FAR from 2,000 pages to 1,500. So why does the person reading every rule expect it to land back near 2,000, and who is in the room deciding what those pages say? Chelsea Roberts sits down with David Mullis, Regulatory Affairs Consultant at Gov Contract Pros, who tracks the Federal Register, OIRA, and the Unified Regulatory Agenda for the small business community. His firm has requested an OIRA 12866 meeting on the RFO, and by his account it is the only contracting industry group doing so. David calls the core idea The Upstream Window. Contractor-binding decisions happen before the proposed rule hits your inbox, and almost no one from industry shows up for them. In this episode you'll learn: • Why the RFO adds new provisions even as it strips others out • What moving forms and examples into the FAR Companion means for notice and comment • Whether commercial-first flexibility helps or hurts small businesses with contracting officers • What a 60-day CMMC pause means against a November implementation date, and why NIST 800-171 Rev 3 is next • How a government shutdown affects new Federal Register postings • Why the SBA size standards methodology white paper is the comment that binds • What Loper Bright changes for the next size standards rule Chapters: 00:00 Introduction 04:20 Is the RFO actually making the FAR shorter? 05:40 What moving forms and examples into the FAR Companion changes 06:50 Will RFO flexibility actually help small businesses win? 11:05 Does the commercial-first push create a security gap? 15:18 CMMC is paused. Should companies stop preparing? 15:52 What changes with NIST 800-171 Revision 3 23:05 How contractors can influence the RFO before it's final 24:38 Will a government shutdown delay the next round of RFO rules? 26:52 Are SBA size standards going up or down? 27:30 The comment that actually changes your size standard 31:35 What Loper Bright means for the next size standards rule #faroverhaul #smallbusinesscontracting #govconpodcast