What Federal Agencies Get Wrong About Developing Their Acquisition Workforce
Federal agencies spend billions of dollars on contract administration every year. The people responsible for managing those contracts — Contracting Officers’ Representatives — are required by law to be trained and certified. FAC-COR exists for a reason.
And yet, the acquisition workforce in many agencies remains a persistent source of risk: contract oversight gaps, requirements that don’t reflect actual needs, performance problems that go unaddressed until they become much bigger problems.
The training requirements aren’t the issue. The way most agencies approach those requirements is.
The Compliance Trap
When training becomes primarily a certification exercise, the goal shifts from building capability to achieving completion. Leaders track hours, not outcomes. Employees check boxes, not competencies.
FAC-COR Level II requires 40 training hours. Those 40 hours can be spread across a dozen online courses — none integrated, most forgotten within 90 days of completion. Technically, the requirement is met. Operationally, the COR still doesn’t know how to manage a complex service contract.
This isn’t a criticism of FAI or the FAC-COR framework — the certification is well-designed and covers what it needs to cover. The problem is how agencies operationalize it. Compliance becomes the objective, and genuine development becomes a secondary concern at best.
What Effective Acquisition Workforce Development Actually Requires
Agencies that build genuinely capable acquisition workforces do several things differently:
They connect training to the actual work.
The strongest development programs don’t treat training and job performance as separate activities. They build in case studies from the agency’s own contract portfolio, scenario exercises that mirror the kinds of decisions CORs actually face, and structured on-the-job application between formal training events.
They develop managers and CORs together.
A COR who has been well-trained but whose supervisor doesn’t understand what good contract oversight looks like is in a difficult position. Effective agencies develop acquisition leadership alongside the workforce — so supervisors can coach, evaluate, and reinforce the right behaviors.
They treat development as continuous, not episodic.
Meeting the minimum CLP threshold is different from maintaining and building competence. Agencies that excel build development into their operating rhythm — regular training events, after-action reviews, communities of practice, mentoring relationships.
They measure outcomes, not hours.
Leading agencies are moving from tracking training completion to assessing actual competency development. That means identifying specific behavioral indicators, building manager observation skills, and using performance data to identify where additional support is needed.
The Role of External Training Partners
Not every agency has the internal capacity to design and deliver high-quality acquisition workforce development on its own. External training contractors play a critical role — and the quality of the vendor relationship matters enormously.
The difference between a vendor who delivers FAC-COR-compliant courseware and a vendor who builds genuine acquisition capability is significant. The former can be procured from a catalog. The latter requires a partner who understands federal acquisition not just at the regulatory level, but operationally — how agencies actually manage contracts, what their workforces struggle with, and where development investment produces the most durable results.
Gotham Government Services has delivered acquisition workforce training for federal clients including the Department of Veterans Affairs. Our approach is built around the principle that compliance and capability are not the same thing — and that well-designed training can achieve both.
A Practical Starting Point
If you’re an ACM or contracting officer assessing whether your workforce development program is actually working, here are three questions worth asking:
- Are your CORs completing training requirements — or genuinely building the skills those requirements are designed to produce? One metric is necessary. Only one of them is sufficient.
- When a COR encounters a challenging contract oversight situation, what resources and support do they have? If the answer is “they call the CO and hope for the best,” there’s a development gap to address.
- How does your workforce development program connect to mission outcomes? If you can’t draw a clear line between the training and the operational performance you’re trying to improve, that’s worth examining.
The federal acquisition workforce carries significant responsibility. Building real capability in that workforce — not just checking certification boxes — is one of the highest-ROI investments an agency can make.
If you’d like to talk about how GGS approaches acquisition workforce development for federal clients, we’d welcome the conversation.
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