302: The FAR Council Just Redefined Small Business—Will You Survive 2025? With Chris Griesedieck Jr.
In this episode Eric sits down with Chris Griesedieck Jr. (GovCon counsel, Venable LLP) to unpack today's FAR Part 19 overhaul: the Rule of Two survives but is discretionary at the task-order level, size re-representation at the task-order level is removed, and 8(a) changes aim to boost post-graduation success. They also break down the CMMC rollout—starting November 10, DoD solicitations will begin requiring Level 1/2 self-assessments, many Level 2 efforts will need third-party certification, and POA&Ms can enable conditional awards (up to 180 days to cure).
Chris shares a practical playbook for REAs and terminations—why recoveries differ under FAR Part 12 (commercial) vs Part 49 (non-commercial), what pre/post-termination and settlement costs are compensable, and why lost profits are almost never in scope absent bad faith. They cover agencies trying to insert new clauses via mods/options (when to insist on consideration or equitable adjustments), upticks in M&A/novations and inter-company work (profit limits with affiliates), and the shifting bid-protest landscape (tougher GAO pleading standards; higher DoD task-order thresholds).
Key Takeaways:
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FAR Part 19—what changed today: Rule of Two saved; discretionary at task-orders; size re-rep at task-order level removed; 8(a) tweaks aim at post-graduation success.
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CMMC timeline & stakes: Starting Nov 10, new DoD RFPs will call for Level 1/2 self-assessments; many Level 2 contracts will need 3rd-party certification; conditional awards require an approved POA&M within 180 days.
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Protect your margin under stress: Use the right REA path (Part 12 vs. Part 49), recover allowable pre-/post-termination costs, and demand consideration/equitable adjustments when agencies add clauses or condition options; track tighter GAO protest standards and higher DoD task-order thresholds.
Learn more: https://federalhelpcenter.com/ https://govcongiants.org/
Chris' Linkedin: https://www.linkedin.com/in/
Website: https://www.venable.com/
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