Comment on FR Doc # 2026-12559

Modernizing Federal Procurement to Strengthen Supply-Chain Resilience, Category Management, and Data Transparency in the U.S. Construction and Infrastructure Sectors Rulemaking: FAR Case 2026-001Docket No.: FAR-2026-0001 Dear Members of the Council, I submit this comment in response to the proposed rule implementing Executive Order 14275 and OMB Memorandum M-25-26. I write as a procurement practitioner with fourteen years of experience structuring category strategy, negotiating multi-billion-dollar framework agreements, and integrating enterprise resource-planning and analytics platforms across capital-project procurement. My comments focus on four areas where the proposed overhaul can be strengthened to deliver measurable savings, transparency, and supply-chain resilience for U.S. federal acquisition. 1. Standardize Category Management Across Executive-Branch Buyers. The proposed revisions to Parts 1, 4, and 39 correctly emphasize simplification and cross-agency consistency. To realize that intent, the Council should adopt an explicit Governmentwide Category Management framework in Part 1, with clearly defined common categories (construction, infrastructure works, information technology, professional services), assigned category owners, and mandatory annual publication of category-level spend and savings performance. A common framework reduces duplicate sourcing effort across agencies, delivers negotiation leverage in a consolidated market, and improves the taxpayer's line of sight into where federal spend actually flows. 2. Codify Machine-Readable Solicitation and Award Data Standards. Part 4 governs administrative reporting. The proposed revisions offer a rare opportunity to require, not merely permit, machine-readable solicitation, award, and modification data across covered acquisitions above the simplified acquisition threshold. Structured data unlocks category-level analytics, benchmarking of unit pricing across agencies, and independent audit of Buy American and small-business set-aside compliance. Without a data standard, the modernization gains projected by this rule will remain unmeasurable. 3. Strengthen Supply-Chain Risk Management in Part 39. The proposed changes to Part 39 begin the important work of consolidating the fragmented supply-chain risk provisions across the FAR. The Council should go further by adopting a tiered supply-chain risk requirement scaled to contract value and criticality, aligning FAR 52.240-3 with NIST SP 800-161r1 and the SECURE Technology Act (41 U.S.C. 4713), and requiring covered contractors to report sub-tier supplier composition on critical items. In parallel, the Council should encourage the use of blockchain-based or equivalently tamper-evident transaction records for high-risk procurements to reduce fraud and to make audit of covered-procurement actions cost-effective. 4. Preserve Access to Global Best Practice. As the FAR is streamlined, care should be taken to preserve its capacity to accept private-sector best-practice innovation in analytics, ERP-driven contract lifecycle management, and blockchain-based supplier verification. The revised Part 39 should retain flexibility for agencies to adopt emerging technologies through market-research findings under Part 10 rather than through prescriptive rulemaking. Doing so lets federal buyers keep pace with the technology curve without requiring a full FAR update every time a new tool matures. Conclusion. The proposed overhaul is a significant and welcome effort. The recommendations above are offered in the spirit of implementation and are intended to help the final rule deliver the simplification, transparency, and supply-chain resilience objectives at the heart of Executive Order 14275. I would be pleased to provide any additional information the Council may find useful. Respectfully submitted, Muhammad Kashif Supply-Chain & Procurement Professional