Small businesses that rely on government contracting are facing a double challenge this season: the new federal rules around the Disadvantaged Business Enterprise (DBE) program and disruptions tied to the government shutdown. Together, these shifts could impact competitive advantages and pipeline visibility, especially firms that rely heavily on their DBE status or those that must continue performing without timely payment.
Below are three steps firms can take to stay informed, reduce risk, and position themselves for stability and growth.
Step 1: Assess Your Contract Portfolio
Start by identifying which of your current or pending contracts might be affected.
The recent DBE guidance changes have altered certification requirements and socio-economic goaling on federal transportation funded projects. Your current contracts are still in place unless you receive a written modification from your prime or contracting officer. FAQs published by US DOT recently clarified that agencies cannot simply decertify all existing DBEs so the roll out of the changes will take place in a more structured and predicable way than originally thought. Read this update linked here by Piliero Mazza.
Review your entire contract portfolio and categorize contracts into three groups:
- Low Risk: Long-term contracts with stable funding sources or limited DBE dependency.
- Medium Risk: Contracts tied to DBE participation goals that may be reevaluated.
- High Risk: Projects dependent on federal funding or DBE certification continuity.
Document each contract’s funding source, performance period, and agency contact. This analysis will help you prioritize which contracts may need immediate action or communication.
Step 2: Conduct Fact-Finding with Primes and Customers
Once you know which contracts could be at risk, the next step is to gather information directly from your contracting partners.
Reach out to:
- Prime contractors, if you’re a subcontractor, ask how they are interpreting and implementing the new DBE guidance.
- Contracting officers or project managers, if you hold contracts directly, to confirm any changes in compliance requirements or reporting expectations.
In light of the shutdown, also ask about payment schedules, work stoppage protocols, and potential extensions. Many agencies will issue guidance or contingency plans — but it’s often up to individual primes or program managers to interpret how those apply at the contract level.
Keep a log of these conversations.
Step 3: Strategize with Your Local APEX Accelerator Advisor
Finally, don’t go it alone. Your local APEX Accelerator advisor is equipped to help you navigate both policy changes and contract uncertainty.
Together, you can:
- Develop a contingency plan for funding disruptions and mitigation plans for vulnerable projects.
- Review new DBE certification guidance related to writing your socially and economically disadvantaged narrative required by OMWBE. Washington APEX advisors helped dozens of firms retain their SBA 8(a) designation after a similar rule change impacted that program.
- Strategize implementing a refreshed marketing plan for your firm.
APEX’s real-time, tailored guidance is offered to Washington firms are no cost.
Moving Forward
Procurement environments shift — but preparation, communication, and partnership remain constant. By assessing risks, conducting fact-finding, and collaborating with your APEX team, your firm can remain both compliant and competitive, even in times of uncertainty.
Additional resources
Federal Government Shutdown: What Contractors Must Do Now!
If the shutdown is affecting your contracts, the first step you should take today is to document everything, especially any costs incurred or delays caused by the shutdown. Accurate records are essential to filing a Request for Equitable Adjustment (REA) and recovering those expenses later. Join Washington APEX Accelerator for two free virtual sessions:
11/4/2025 2 PM Government Shutdown: What to do now and how to recover
11/13/2025 2 PM Surviving Difficult Contracting Times
Both classes will cover practical steps to minimize losses, strengthen your documentation, and protect your business during federal shutdowns.
