Good Afternoon. The brief went quiet for two weeks while I was on the road. That is the longest gap since the relaunch, and I don’t intend to repeat it. The tracker is caught up. The July 14 prediction gets graded below, two weeks late, and the lateness is explained alongside the result. Tuesday and Thursday resume today.

Executive Order 14402, signed April 30 and published at 91 FR 24325, gave every agency head 90 days to review the agency's ten largest non-fixed-price contracts and to push them toward fixed prices. Ninety days from April 30 was July 29.

If you hold one of your customer's biggest cost-type contracts, somebody has already read your file.

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Section 2(c) of the order runs a single paragraph. It gave each agency head 90 days to review the agency's 10 largest non-fixed-price contracts by dollar value and to seek to restructure or renegotiate them toward fixed prices and performance-based incentives. April 30 plus 90 days was July 29.

The subsection underneath it is the one most people skipped. Section 2(c)(ii) exempts research and development work, pre-production development for major systems acquisition, and anything supporting an emergency or contingency operation. At the Department of War, that carve-out removes most of what comes to mind when somebody says large cost-plus contract. Major system development drops out before the counting starts. What is left to rank is services. Logistics, engineering support, IT, program management, base operations.

Section 2(d) sends the results to the Director of OMB. Agencies report the number of non-fixed-price contracts they approved, the value, and the written justification for each, and the first report ran on that same 90-day clock. Nothing in the order asks anyone to publish anything, and nobody has. Do not read the quiet as agencies dragging their feet. Reporting to OMB is what the order told them to do.

The rest of the paper trail is arriving on time. DoD issued Class Deviation 2026-O0045 Revision 1 on July 15, making fixed-price the default and setting up the justification regime that goes with it. Two categories of work got a runway. One is solicitations issued before July 15 with award planned after that date. The other is existing contracts and orders that still had at least 18 months of performance left as of July 15. Both need an approved justification by July 15, 2027. Every renegotiation conversation coming out of the top-ten reviews has to fit inside that window.

The approval thresholds tell you who actually feels this. Under Section 2(b)(ii) a non-fixed-price contract needs the agency head's written approval above $100 million at the Department of War, $35 million at NASA, $25 million at DHS, and $10 million at every other agency in the government. A $12 million cost-plus services contract at Labor crosses a line that a $90 million contract at DoW does not.

Now apply that to a top-ten list at an agency that does not buy on the DoW scale. Strip out the R&D exemption, rank what remains by dollar value, and the tenth name might be a $30 million services contract held by a company of two hundred people. That company has no acquisition counsel on retainer and has never heard of Class Deviation 2026-O0045. It is on a list next to Booz Allen.

A review requirement with no publication requirement produces lists that live entirely inside the building. Programs find out they were on one when a contracting officer asks for a meeting.

We started pushing the conversion-analysis position on July 14. That was preparation then. It is catch-up now.

The review that reaches your existing contracts already happened, and nobody is going to tell you whether your program was in it.

Two dockets close Friday.

The CMMC Reform RFI closes Friday, August 14 at noon Eastern. Submission is by email only, to the two addresses in the SAM.gov notice, with "Reforming CMMC and Reducing Compliance Burden for the Defense Industrial Base (DIB)" in the subject line. The notice states that only submissions reaching Leanne Condren will be considered and that late responses will not be considered at all. Five of the seven questions ask about cost, administrative burden, or what should replace third-party assessment. Whatever the task force recommends in September is built from those answers.

The ITAR Part 130 comment window closes the same day. The proposed rule (91 FR 35926, RIN 1400-AF94, docket DOS-2026-0562) moves reporting of political contributions and fees from a transaction-by-transaction filing to an annual one, and it roughly doubles thresholds that have not moved since July 1993. Contributions go from $5,000 to $10,000. Fees and commissions go from $100,000 to $200,000. The covered-sale trigger goes from $500,000 to $1,000,000. File through Regulations.gov under the docket number or email DDTC with the RIN in the subject line. State says comments arriving after the 14th may still be considered where feasible, which is a softer door than the CMMC noon cutoff, and not one worth relying on.

Thursday's issue is the last one that lands before either record closes.

Next week: the AFWERX Specific Topic cycle closes August 18, the DARPA SBIR wave closes August 19 at noon, and PCB rulemaking comments run to August 31.

Pro members: every window, tracked with our notes → Hub link

Results from our last issue. On July 28, we asked whether your company could map its critical-material supply chain below the first tier.

Seven responses. That is thin, and I am reporting it rather than reading anything into it. The two-week gap is the obvious reason, and I am not going to dress it up as anything else. The one thing I would want to see hold up is that both middle answers drew zero.

Everyone who answered claimed either full visibility to raw materials or no visibility at all, with nobody in between. We will run the question again once the cadence is back and see whether that survives a real sample.

This issue's question. One tap, anonymous, results Thursday.

Record: 1-0.

On July 14, we called that at least 20 of the 24 CFO Act agencies would post Part 16 deviations to the acquisition.gov guide by July 31. Our count this morning came to 21 of 24. The call hits. Interior, USAID, and the Small Business Administration are the three not listed.

Two things about that count that a reader checking our work would find on their own.

We counted on August 11, not July 31. Deviations pile up rather than lapse, so 21 today only settles the July 31 question if those postings predate the deadline. The Part 16 page shows a section update of July 1 and a footer reading last updated July 28, which puts the listing in its current state three days before the deadline. That footer is the best public evidence there is, because acquisition.gov does not date the individual agency entries at all. Each one is a hyperlink to a signed PDF. The dates are inside the documents.

Three of our 21 got there through combined filings rather than standalone Part 16 memos. HHS and SSA filed multi-part bundles that include Part 16, and Commerce filed a single document covering Parts 1 through 53. We counted all three. A stricter reading drops them, lands on 18, and grades this call a miss. Worth knowing before you rely on the number. The other limit is one we published on July 16. Counting the guide is not the same as counting the agencies, because an agency can carry a signed deviation on its own site that never gets listed.

Interior, USAID, and SBA are missing from the guide, which is not the same as sitting still.

The DRPM call expires Saturday. We made it on July 7, and it requires a director named by August 15, from outside the traditional service acquisition corps, with an announced nominee counting as named. Day 43 and there is no name and no interim; the Pentagon will confirm. August 15 is a Saturday, which leaves Friday as the last working day it can happen on.

The NDAA conference call runs to Thanksgiving. The House committee advance in July keeps that one a real bet.

The Reset's 90-Day Watchlist mapped every deadline and decision point coming out of the July report. Five of them land inside the next ten days, including both Friday dockets and the DRPM deadline the day after. The Watchlist is why this week arrived on a calendar instead of as a surprise. Pro is the report library, the live tracker, the Monday Huddle, and a direct line to us.

The top-ten reviews are finished, and the results are sitting at OMB. Somebody reading this is running a program that was on one of those lists and will never be shown it. If a renegotiation or restructuring conversation has already reached you, I want to know what it sounded like.

Hit reply. Anonymity guaranteed. What you send becomes the ground truth for how we cover the next year of this.

Semper fi,

— Justin