Since 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.
Federal Government Shutdown
Without a continuing resolution or budget agreement, the Federal Government Shutdown began October 1, 2025.
For Federal Employees:
If you are a federal employee, please consult your agency’s contingency plan for guidance on operations and staffing during a shutdown. Agencies should, under OMB Circular A-11, publish contingency procedures on their websites.
For Contractors:
While contractors may not be directly subject to federal employee furloughs, a shutdown could still include the following impacts:
- Suspension or delay of federally funded contracts.
- Work stoppages if federal oversight or facility access is required.
- Delays in invoice processing or payments.
A shutdown may also affect projects performed for state and local agencies that rely on federal grants or financial assistance, as well as subcontractor work tied to federal funding.
Potential Actions for Contractors:
- Review contracts for funding clauses and stop-work provisions.
- Coordinate with Contracting Officers (COs) to confirm funding status and determine which programs will continue.
- Prepare contingency plans for employee reassignments, cash flow disruptions, and potential performance delays.
- Review relevant FAR clauses (e.g., FAR 52.232-18, Availability of Funds).
- Document all communications and impacts.
- Do not incur costs on unfunded work unless explicitly authorized.
For additional resources and guidance, click here and continue to monitor this page.
U.S. DOT 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. The Department of Transportation is accepting public comments on the rule through November 3, 2025.
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
Industry Information/Resources:
Federal Executive Actions
- 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 (GSA) (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
- Increase in Tariff Rates on Steel and Aluminum (White House Proclamation) - On June 3, 2025, President Trump doubled tariffs on imported steel and aluminum from 25% to 50%, citing national security concerns and the need to counteract foreign dumping practices (as of 6/5/2025)
- Temporary Pause in Reciprocal Tariff Rates with China (White House Executive Order) - On May 12, 2025, President Trump signed an executive order reducing tariffs on imports from China for 90 days, effective May 14 (as of 5/13/2025).
- Pause in Tariff Increases for Certain Goods from Mexico, Canada (White House Executive Order) – President Trump announces a pause on tariff increases for goods from Mexico and Canada that are covered under the United States-Mexico-Canada Agreement of 2020. (as of 3/7/2025)
- Tariffs on Canada, Mexico, China Take Effect (White House Executive Order) - President Trump implements an additional 25% tariffs on imports from Canada and Mexico, and a 10% tariff on imports from China. These went into effect on March 4, 2025 (as of 3/4/2025)
- Pending Steel, Aluminum Import Tariffs (White House Executive Order) - President Trump signed executive orders implementing 25% tariffs on steel and aluminum imports, effective March 12, 2025 (as of 2/11/2025)
Industry Response Resources and News
- DOT’s DBE Program Faces Legal Challenge (Engineering News-Record) - The U.S. Department of Transportation declared its Disadvantaged Business Enterprise (DBE) program “unconstitutional” following a legal challenge, signaling possible widespread changes to longstanding federal procurement practices (as of June 2, 2025)
- Monitoring the Trump White House’s Impact on Engineering (ACEC) – Monitoring White House Orders, Tariffs, Congressional Resources, and Agency Actions that impact engineering and design services industries. (As of 3/3/2025)