Blog · Services Contracting

H.R. 5235 Would Make Contracting Officers Justify Degree Requirements in Writing

Chris A. Grable · August 6, 2026

Labor categories in federal services contracts have long leaned on degrees as a shorthand for capability. A bill now one step closer to the Senate floor would make that shorthand harder to use. On 6 August the Senate Homeland Security and Governmental Affairs Committee voted 10 to 0 to advance the Skills-Based Federal Contracting Act, H.R. 5235, which the House had already passed in February.

What the bill does

• Default rule: a federal solicitation could not set minimum education standards for contractor personnel.
• Exception: the contracting officer may impose one by providing a written justification.
• Guidance: the Office of Management and Budget would have 180 days after enactment to issue implementing guidance, and that guidance must push contracting officers to weigh alternatives to degree requirements.

Why services contractors should care

Degree-based qualifications do more than screen résumés. They set who a company can propose into a labor category and the rate it can charge for that person. Remove the degree floor and the evaluation weight shifts toward experience and demonstrated skill. Today the bidder carries the burden of meeting a degree floor; under the bill, the contracting officer would carry the burden of defending one.

What to do before it becomes law

As of this August post, the bill still needed a Senate vote and enactment, and OMB guidance would follow on its own clock. (Update, 31 October 2026: the Senate passed it without amendment on 30 September; see our follow-up. Congress.gov had not recorded signature as of this update.) UDC recommends that services firms begin documenting the experience and skills of staff who hold the work but not the credential, and review how their rate structures depend on degree tiers, so they are ready to propose and price on skills when solicitations change.