Blog · Workforce Policy

Skills-Based Federal Contracting Act Clears Congress: Review Your Labor Categories Now

Chris A. Grable · October 1, 2026

Congress has finished work on the Skills-Based Federal Contracting Act, H.R. 5235. The Senate passed it by unanimous consent on 30 September with no amendments. Earlier, the House approved it in February and the Senate committee vote in August was 10 to 0. Because both chambers passed identical text, it now goes straight to the President's desk.

What the bill changes

A solicitation could no longer impose a minimum education requirement on contractor staff without a written justification from the contracting officer. OMB would then have 180 days after enactment to publish guidance directing contracting officers to look at alternatives to degree requirements.

The legislative record

Rep. Nancy Mace of South Carolina introduced the Skills-Based Federal Contracting Act of 2025 on 9 September 2025, and it was referred to the House Committee on Oversight and Government Reform. In the Senate it went to the Committee on Homeland Security and Governmental Affairs, which ordered it reported on 6 August 2026. Senator Paul reported it without amendment and without a written report on 14 September, and it was placed on the Senate calendar as Calendar No. 571. The Senate passed it on 30 September (Congressional Record S5295), and the action log shows the Senate's message sent back to the House on 14 October.

Two procedural points matter for planning. First, passage is not enactment: the enrolled bill still has to be signed by the presiding officers and presented to the President, and as of 31 October Congress.gov listed the bill's status as Passed Senate, with no presentment recorded. Second, OMB's 180-day clock for guidance runs from enactment, so the date that matters for solicitations has not been set yet.

Why to act before signature

A bill that passed both chambers with no recorded objection is unlikely to stall now. UDC recommends preparing now and checking the enacted text, its effective provisions, OMB guidance and each solicitation, since those milestones may fall on different dates.

UDC recommends reviewing every labor category that relies on a degree. For each one, identify the experience, certification or credential that demonstrates the same skill. After enactment, that substitution becomes the question a staffing plan has to answer, and the companies that work it out in advance will write the stronger plans.

Closing Rate covered the bill earlier in A Bill to Strip Degree Requirements.