Your First Federal Contract: The First 90 Days

The moment a federal contract is awarded, the clock starts on dozens of obligations — many of which have no grace period. The companies that execute well on their first contract build past performance, earn strong CPARS ratings, and position for recompetes and larger awards. The ones that stumble often do so quietly and don't understand why the next award didn't come.

Day 1–7: Establish Command and Control

• Identify the Contracting Officer (CO): This is the government official with legal authority over your contract. Only a CO can authorize changes to scope, schedule, or budget. Learn their name, contact information, and the process for formal communication.
• Identify the Contracting Officer's Representative (COR): The COR manages day-to-day technical aspects. They review deliverables, answer technical questions, and write your CPARS rating. This working relationship determines whether you get "Exceptional" or "Satisfactory."
• Understand modification authority: What changes require a formal contract modification versus what the COR can authorize informally? Doing work outside your contract scope without a modification is an unauthorized commitment — the government does not have to pay for it.
• Identify your invoice submission portal: WAWF (Wide Area Workflow) for DoD, IPP (Invoice Processing Platform) for most civilian agencies. Set up your vendor account immediately — this takes time and you need it before the first invoice period closes.
• Read every clause in the contract: This sounds obvious. Almost no one does it. Start here before anything else.

Week 2–4: Build the Clause Register

The clause register is a simple table, maintained as a live document throughout the contract, that maps every FAR/DFARS clause number to four things: what it requires, the compliance cadence (daily/monthly/annually/at closeout), the internal owner at your company, and current status (compliant or action needed).

This sounds bureaucratic. It is. It is also the single most effective tool for never missing an obligation — and for proving to a DCAA auditor that your company operates with discipline.

Priority clauses for the clause register on Day 1:

• DFARS 252.204-7012 (cyber incident reporting — 72-hour clock, active from Day 1)
• FAR 52.222-41 (Service Contract Act, if applicable — prevailing wage compliance)
• FAR 52.219-14 (Limitation on Subcontracting, if a set-aside contract)
• DFARS 252.232-7003 (WAWF invoicing requirement)
• FAR 52.215-2 (Audit and Records — how long you must retain contract documentation)

Month 1–2: Map Your Accounting to the Contract

Every contract has Contract Line Item Numbers (CLINs) — individual deliverables with associated prices. Your accounting system must be able to track all costs by CLIN. Labor, materials, and Other Direct Costs (ODCs) must be traceable to the specific CLIN they support. Commingling costs across CLINs creates audit exposure and billing problems.

Contemporaneous timekeeping is mandatory. If you or anyone charging to this contract records time, it must be entered daily — not reconstructed at the end of the week. Retroactive timekeeping is the single most common finding in DCAA audits. It is also the easiest to avoid: enter time every day, immediately after the work is done.

Month 2–3: Install the Compliance Cadence

Most contract compliance obligations run on a schedule. Put them on the calendar as hard deadlines before you forget they exist:

• Certified payroll (WH-347 form): Required on Davis-Bacon or SCA-covered contracts; submitted weekly
• SCA recordkeeping: Service Contract Act wage and benefits documentation must be maintained and available for audit at any time
• DFARS 252.204-7012 attestation: Cyber incident reporting obligations are live 24/7 from Day 1; a reportable incident must be reported to DoD within 72 hours
• Progress reporting: Most contracts require monthly or quarterly status reports to the COR — treat these as hard deadlines, not suggestions
• Subcontractor approvals: If your contract requires government approval before adding a subcontractor, getting approval after the fact is an unauthorized commitment

Protect Your CPARS Rating

Your CPARS rating is your public federal performance record. Future contracting officers read it before awarding. Future primes read it before subcontracting to you. A single "Marginal" rating can suppress your win rate for years.

• Request informal feedback from the COR monthly — not just at formal rating time
• Address any concerns in writing so the record shows your responsiveness
• When the formal rating period opens, read every word of the preliminary rating
• If you disagree, submit a formal contractor comment — this becomes part of the permanent record alongside the government's narrative

Start the Next Bid Now

The moment you are in performance, you have something you didn't have before: a relationship with a CO and a COR, an agency that knows your name, and past performance actively building. Use it immediately.

• Attend the next industry day at this agency
• Ask the COR what upcoming requirements are in the planning pipeline
• Identify the next IDIQ or GWAC vehicle in your category
• Start Sources Sought response cadence for the next opportunity before this one closes