CMAA Federal Policy Watch

CMAA Advocacy LogoSince its inception in 1982, CMAA has been dedicated to assisting our members, and the entire program and construction management community, realize project, program, and professional success. Currently, the industry is experiencing a period of significant change in federal policy, including shifts in Executive/Agency Guidance, trade policies, and regulatory requirements. CMAA understands that our members need access to reliable information to navigate these developments effectively. 

This Federal Policy Watch serves as a centralized location for information about federal actions that may impact PM/CM professionals. CMAA maintains this hub as a service to our members, with the goal of providing access to primary sources and verified information. This hub will not be exhaustive, and CMAA will work to update resources as new developments occur. 

CMAA has and will continue to monitor developments related to policies that may impact our members and the program and construction management industry. The information linked here is provided for information purposes only and primarily includes official documents and guidance. If any linked resource contains analysis or opinion, please note that it does not reflect the views of CMAA as an organization. 

If you have further questions regarding the information posted, would like to flag issues or resources impacting your work, or have additional questions please contact us at advocacy@cmaanet.org. 

USDOT Interim Final Rule on Disadvantaged Business Enterprise (DBE) Program

Background

On October 3, 2025, the U.S. Department of Transportation issued an Interim Final Rule (IFR) modifying the Disadvantaged Business Enterprise (DBE) and Airport Concessions DBE programs. The rule took effect immediately upon publication, removing race- and gender-based presumptions of social and economic disadvantage, and now requires all applicants to demonstrate individualized proof of disadvantage. Every certified DBE firm must be reevaluated under this new standard before agencies can set or count DBE goals.

What’s Changed
Under the IFR, certification will now rely on each applicant’s personal narrative and financial documentation to establish disadvantage based on specific barriers and economic impacts, rather than group-based presumptions. State and local recipients administering the program must temporarily pause DBE goal setting and reporting until reevaluations are complete.

CMAA Response
CMAA recognizes that this change creates significant uncertainty for both DBE-certified firms and the owners responsible for administering DBE programs. CMAA is closely monitoring developments, coordinating with industry partners, and engaging with affected member firms to understand and address the practical implications of these changes. CMAA is also gathering information from state transportation departments and Unified Certification Programs nationwide to keep members informed.

Next Steps for Members
CMAA is conducting outreach to DBE-certified member firms to understand specific challenges and resource needs. This section of the Federal Policy Watch will provide updates, guidance, and additional resources as available.
For questions or to share how this rule may affect your work, please contact advocacy@cmaanet.org.

U.S. DOT Guidance on the IFR

U.S. DOT FAQs on IFR

Updates

Industry Information/Resources:

Federal Executive Actions

  • FAR Council Publishes Proposed "Revolutionary FAR Overhaul" Rules for Comment (Acquisition.gov) - The Federal Acquisition Regulation (FAR) Council published four proposed rules under the Revolutionary FAR Overhaul covering multiple parts of the Federal Acquisition Regulation, with public comments due July 23, 2026. CMAA members with work related to federal agency procurement may be impacted by these revisions. (as of 6/23/2026)
     
  • SBA Proposes Revisions to 8(a) Business Development Program Eligibility Rules (Federal Register) - The Small Business Administration issued a proposed rule that would remove the rebuttable presumption of social disadvantage for individually owned firms seeking eligibility for the 8(a) Business Development Program and establish revised standards for individuals to demonstrate social disadvantage. The proposed rule does not apply to entity-owned firms, including those owned by tribes, Alaska Native Corporations, Native Hawaiian Organizations, or Community Development Corporations, and comments are due July 13, 2026. (as of 6/11/2026)
     
  • GSA and OMB Deregulation Initiative (U.S. General Services Administration) - The U.S. General Services Administration (GSA) and Office of Management and Budget (OMB) introduced a public initiative inviting suggestions for eliminating or modifying existing federal regulations. The effort aims to enhance government efficiency by reducing regulatory burden. (as of 4/16/2025)
     
  • Executive Order Reforming Federal Procurement (White House Executive Order) - President Trump’s executive order directing a comprehensive overhaul of the Federal Acquisition Regulation (FAR) to streamline federal procurement processes. Revisions to be implemented within 180 days. (as of 4/15/2025)
     
  • Executive Order Consolidating Federal Procurement (White House Executive Order) - President Trump’s executive order consolidating the procurement of common goods and services under the General Services Administration. (as of 3/20/2025) 
     
  • Executive Order Tracker (Gibson Dunn) – A searchable and filterable resource that catalogs and summarizes executive orders and significant announcements from the White House, providing insights into the agencies involved and subjects covered. (as of 3/3/2025)
     
  • RIF Watch (Government Executive) – Updating information on federal agencies implementing reductions in force (RIFs), detailing which departments are laying off federal workers and the scope of these actions. (as of 3/1/2025) 

Trade and Tariff Developments

Industry Response Resources and News