OMB Greenlights More Subcontract Consent Busywork
Published Date: 3/13/2025
Notice
Summary
The government is asking contractors to keep sharing info when they want to hire subcontractors or review their buying systems. This helps make sure everything is fair and smart with public money. If you’re a contractor working with the government, get ready to keep submitting these details, and don’t forget to send your comments by April 14, 2025!
Analyzed Economic Effects
5 provisions identified: 0 benefits, 5 costs, 0 mixed.
Detailed Subcontract Consent Filings Required
If you are a prime contractor seeking the contracting officer's written consent to award a subcontract under FAR 52.244-2, you must submit specific information including: a description of the supplies/services being subcontracted; the type of subcontract; the proposed subcontractor; the proposed price; any required certified cost or pricing data and Certificate of Current Cost or Pricing Data; any required Cost Accounting Standards Disclosure Statement or Certificate; and a negotiation memorandum covering elements (A) through (G) listed in the clause.
Purchasing System Reviews Triggered at $25 Million
An administrative contracting officer (ACO) will consider a Contractors' Purchasing System Review (CPSR) if a contractor's sales to the Government are expected to exceed $25 million during the next 12 months (excluding certain competitively awarded fixed-price and commercial sales). The ACO will determine at least every three years whether a purchasing system review is necessary, and agency heads may raise or lower the $25 million review level.
Estimated Annual Compliance Burden
The information collection estimates 2,515 respondents, 7,065 total annual responses, and 49,635 total annual burden hours for the Subcontract Consent and Contractors' Purchasing System Review collection (OMB Control No. 9000-0149).
Advance Notice Required Before Placing Certain Subcontracts
Prime contractors must notify the contracting officer reasonably in advance of placing any subcontract or modification for which consent is required under FAR 52.244-2. This advance notification is used to ensure statutory compliance under 10 U.S.C. 3322(c) and 41 U.S.C. 3905.
Short Timelines for Responding to Review Findings
If recommendations are made to improve an approved purchasing system, contractors must reply within 15 days with their position. If approval is withheld or withdrawn, the ACO must inform the contractor within 10 days of the in-plant review and request a corrective action plan to be furnished within 15 days.
Personalized for You
How does this regulation affect your finances?
Personalize government policy and PRIA will tell you what this federal register document means for your household, plus every other regulation we track. PRIA reads each provision against your financial profile to show you exactly what matters to your wallet.
Key Dates
Department and Agencies
Related Federal Register Documents
2026-19160, Federal Acquisition Regulation: Revolutionary Federal Acquisition Regulation Overhaul Parts 16, 17, and 35
The government is shaking up how it buys stuff by simplifying key contract rules in parts 16, 17, and 35 of the Federal Acquisition Regulation. This change affects federal agencies and contractors, aiming to cut red tape and save taxpayer money. Comments on the proposed changes are open until October 19, 2026, so get ready to weigh in!
2026-20270, Information Collection; Presolicitation Notice and Response
The government wants to keep collecting info about presolicitation notices, which help agencies plan buying stuff. They’re asking the public to share thoughts on how useful this info is and how to make it easier to provide. This extension would last three more years, with comments due by December 1, 2026, but no new costs are expected.
2026-20271, Information Collection; Federal Acquisition Regulation Part 11 Requirements
The government agencies in charge of buying stuff (like DoD, NASA, and GSA) want to keep collecting info under a rule called FAR Part 11 for three more years. They’re asking the public to share thoughts by December 1, 2026, on how to make this info collection easier and more useful. This won’t cost extra money but helps keep government buying smooth and clear.
2026-20126, Submission for OMB Review; Certain Federal Acquisition Regulation Part 28 Requirements
If you’re a contractor working with the federal government, you’ll want to know that some paperwork rules about bonds and payment protections are up for review and extension. These rules help make sure contractors provide the right guarantees on projects, especially construction ones over $35,000. Comments on these rules are open until November 2, 2026, so get ready to weigh in if this affects you!
2026-20128, Submission for OMB Review; Preaward Survey Forms (Standard Forms 1403, 1404, 1405, 1406, 1407, and 1408)
The government is asking to keep using six preaward survey forms that help check if contractors can do the job before signing a contract. This affects contractors and contracting officers who need to prove financial strength, reliability, and ability to deliver on time. Comments on this request are open until November 2, 2026, with no new costs expected.
2026-20127, Submission for OMB Review; Acquisition 360 Voluntary Survey
The government is asking for approval to keep using the Acquisition 360 Voluntary Survey, which lets companies give feedback on how the government handles contract talks and debriefings. This survey helps agencies improve how they work with vendors before awarding contracts. If you’re a business interested in government contracts, your input matters! Comments on this plan are open until November 2, 2026, and there’s no cost to participate.
Previous / Next Documents
Previous: 2025-04001, Information Collection; Travel Costs
The Department of Defense, GSA, and NASA want to keep collecting info about travel costs from contractors for three more years. They’re asking the public to share thoughts by May 12, 2025, to make sure this info helps the government and isn’t too much work. No new fees or changes in timing—just an extension to keep things running smoothly.
Next: 2025-04003, Submission for OMB Review; Certain Federal Acquisition Regulation Part 4 Requirements
If you’re a contractor or offeror working with the government, you’ll need to keep submitting your Taxpayer ID and Unique Entity Identifier info just like before, but with some updated rules to keep things accurate and smooth. The government is asking for a quick review and approval of these info rules by April 14, 2025, with no new costs involved. This helps everyone stay on the same page and keeps contracts running without a hitch!