Winning a federal contract means taking responsibility for the work. But does it also mean starting over with the people doing it?
When a service contract changes hands, the incoming contractor takes over a program with its own history and established ways of operating. The employees who have been delivering those services may understand aspects of the program that aren’t immediately apparent to the company taking over.
That puts the new contractor in an interesting position. It has won the opportunity to bring its own approach to the work, but some of the people best equipped to help it succeed may already be there. The question is how to recognize that value without assuming the existing workforce is necessarily the right fit for everything the contractor intends to accomplish.
Until recently, federal policy helped shape that decision by requiring certain successor contractors to offer qualified incumbent employees an opportunity to remain on the job. Those requirements have since been rescinded, giving affected contractors more discretion over workforce retention.
So when the decision is no longer dictated by that particular requirement, how should a contractor decide who stays?
When the Rules Change, the Decisions Don’t Disappear
In November 2021, Executive Order 14055 established a right-of-first-refusal framework for qualified employees working on certain federal service contracts. When a covered contract changed hands, the incoming contractor was generally required to offer eligible employees of the outgoing contractor an opportunity for employment, subject to exceptions.
The idea was to reduce workforce displacement and preserve experience during contract transitions.
That changed in January 2025, when the executive order was revoked. The Department of Labor subsequently rescinded its implementing regulations that December, removing the nondisplacement requirements established under the order.
But removing a requirement doesn’t remove the considerations behind it. Experience, continuity, and the ability to deliver on a federal contract still matter. What’s changed is that affected contractors have greater discretion to weigh those factors against their own plans for the program.
And that raises a question worth considering: how much of a program’s success belongs to the organization managing it, and how much belongs to the people who have spent years doing the work?
The Knowledge That Doesn’t Appear on a Resume
Imagine taking over environmental support services at a federal installation where the same specialists have worked for years. You could decide to start fresh, recruiting professionals with comparable credentials and technical experience. On paper, there might be little separating the two teams.
But how do you compare that experience when an incumbent specialist knows why a previous remediation strategy failed or can recognize a recurring issue before it becomes serious? Suddenly, two equally qualified professionals aren’t quite so equal after all.
A replacement may be every bit as capable, but learning the installation’s history and building the relationships needed to work effectively there takes time. That’s a cost of starting fresh that doesn’t necessarily appear in a staffing proposal.
Still, knowing a program well isn’t the same as knowing how to improve it. An incoming contractor may have won the award by proposing changes that require expertise the existing team doesn’t have. Retaining everyone could preserve valuable experience, but it could also limit the very improvements the contractor promised to deliver.
The difficult part is recognizing the difference. A long tenure shouldn’t automatically guarantee someone a place on the new team, any more than a new contract should automatically put that place in question. What matters is the contribution each person can make to the work ahead.
Of course, identifying the employees worth retaining is only part of the decision. The contractor still has to convince them to stay.
The Workforce Gets a Vote, Too
For employees who have spent years supporting the same federal program, a change in contractors can put them in an unusual position. They may be asked to continue doing essentially the same job, at the same location, but under an employer they had no part in choosing.
And while the incoming contractor may see retaining those employees as the safest way to preserve continuity, the employees may see the transition differently. A new employer means reconsidering compensation, leadership, and whether the opportunity is still the right fit. For some, it may be the first reason they’ve had in years to seriously explore other options.
That difference in perspective can expose a weakness in an otherwise carefully developed transition plan. A contractor may have identified exactly which employees it wants to retain, but those plans mean very little if the employees have already decided to move on.
Conversations with incumbent employees, as early as applicable requirements allow, can reveal more than who’s willing to accept an offer. They can also give the incoming contractor a better understanding of the team’s concerns, expectations, and reasons for staying. That information can influence both retention decisions and the recruiting that may be needed to support them.
Building a Team Without Starting From Scratch
By the time a contractor has a clearer picture of who intends to stay, it may also have a better understanding of where the existing workforce could be strengthened. Some positions will require replacing experienced specialists, while others may be an opportunity to introduce capabilities that support the new approach.
Neither decision should be made in isolation. Bringing in new professionals can address skill gaps, but it also introduces a learning curve. Retaining experienced employees can preserve valuable knowledge, but those employees still need to work effectively under new leadership and alongside new colleagues. The success of the transition depends on how those decisions come together, not simply on how many positions are filled.
There may also be contractual obligations that limit how much disruption the program can absorb. Federal Acquisition Regulation 52.237-3, Continuity of Services, addresses the orderly transfer of certain services vital to government operations. When included in a contract, it establishes transition responsibilities and can require phase-in and phase-out services for up to 90 days after the previous contract expires. Although the clause doesn’t require successor contractors to hire incumbent employees, it reinforces an important distinction: flexibility over staffing doesn’t eliminate responsibility for continuity.
That makes access to specialized talent particularly valuable during a transition. For contractors without an established recruiting pipeline, a staffing partner familiar with government contracting can help identify qualified professionals before vacancies or new requirements begin affecting the program.
The opportunity isn’t simply to assemble a replacement workforce. It’s to build on the experience already available while making the changes necessary to deliver something better.
What Should Actually Change?
A new contract gives a company the authority to make changes. It doesn’t automatically make every change an improvement.
A contractor can spend months studying a federal program before winning the award and still have plenty to learn from the people who have spent years keeping it running. Their experience may reveal strengths worth preserving, problems that need attention, or opportunities that weren’t obvious during the proposal process.
At Certis Government Services, we believe effective workforce planning starts with understanding those distinctions. Our role is to help contractors find qualified professionals whose experience and capabilities match what the program actually needs, whether that means supporting an existing team or bringing in new expertise.
With federal nondisplacement requirements rescinded, certain successor contractors have greater freedom to make those decisions. That freedom makes good judgment more important, not less.
Perhaps the most valuable thing an incoming contractor can bring to a federal program isn’t an entirely different workforce, but the ability to recognize what deserves to be different.
After all, there’s little value in starting over if you haven’t taken the time to understand who and what you’re starting with.