Skills-Based Federal Contracting Act of 2025
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Would bar federal contract solicitations from imposing minimum college-degree or other educational requirements on contractor personnel unless the contracting officer provides a written justification explaining why the agency's needs cannot otherwise be met.
The bill would shift federal procurement toward skills-based hiring by requiring justification for degree requirements — a move that could open competition to workers with trade experience or alternative credentials rather than formal degrees.
What this bill would do
What it would do
The bill would amend title 41 of the U.S. Code to prohibit federal contract solicitations from specifying minimum educational requirements — including associate's, bachelor's, graduate, or professional degrees, or specified coursework — for proposed contractor personnel, unless the contracting officer includes a written justification in the solicitation explaining why the agency's needs cannot be met without such a requirement. The prohibition covers requirements that can be satisfied by education alone, by education or experience, or by a combination of both.
The bill would also require the Office of Management and Budget to issue implementing guidance to agencies within 180 days of enactment, including instructions encouraging contracting officers to use alternatives to degree requirements. The new rules would apply to solicitations issued 15 months or more after enactment. A separate provision would repeal an earlier defense-authorization statute that had shaped IT contractor education standards. The Government Accountability Office would be required to evaluate agency compliance and report to Congress within three years.
Key provisions
- 1Would prohibit federal contract solicitations from requiring minimum educational credentials for contractor personnel unless the contracting officer provides written justification of why the agency's needs cannot be met otherwise.
- 2Would define 'education requirement' broadly to include requirements that can be satisfied through education alone, education or experience, or a combination of both.
- 3Would require the OMB Director to issue implementing guidance to executive agencies within 180 days, including instructions encouraging alternatives to degree requirements.
- 4Would apply the new prohibition only to solicitations issued 15 or more months after enactment, allowing a transition period.
- 5Would repeal Section 813 of the Floyd D. Spence National Defense Authorization Act for Fiscal Year 2001 once the OMB guidance takes effect.
- 6Would require the Government Accountability Office to submit a compliance evaluation to Congress within three years of enactment.
Who would be affected
Federal contracting officers across all executive agencies, who would need to justify any degree requirement they include in a solicitation. Bidding contractors and their employees — particularly workers without traditional college degrees but with relevant work experience — who could gain access to federal contract competitions they might otherwise be screened out of. The Office of Management and Budget would be directed to write and distribute implementing guidance.
Why it matters
Workers with relevant skills or experience but no college degree could become newly eligible to work on federal contracts, broadening the labor pool for government work. Contracting officers would bear a new administrative burden of written justification each time they want to retain a degree requirement, which may discourage routine use of educational credentials as a proxy for competence.
What would change
Changes to existing law
Amends Title 41, United States Code, Chapter 33 (Sec. 2(a))
Adds a new section 3313 prohibiting minimum education requirements in federal contract solicitations unless a written justification is provided.
Repeals Section 813 of the Floyd D. Spence National Defense Authorization Act for Fiscal Year 2001 (Public Law 106-398) (Sec. 2(e))
Repealed upon the effective date of the OMB guidance required by the bill.
Agencies directed to act
Effective dates
- OMB must issue implementing guidance to executive agencies
- Prohibition on minimum education requirements applies to solicitations issued on or after this date
- Repeal of Section 813 of the Floyd D. Spence NDAA for FY2001 takes effect
- GAO compliance evaluation due to Congress
Funding and costs
Congressional Budget Office estimate
CBO estimates H.R. 5235 would have a negligible effect on the federal deficit, with any spending from reporting requirements costing less than $500,000 over the 2026–2031 period.
CBO estimates that H.R. 5235 would have a negligible effect on the federal budget. The bill would prohibit federal agencies from requiring minimum education credentials in contract solicitations and instead mandate skills-based assessments, with the Office of Management and Budget issuing guidance and the Government Accountability Office completing an evaluation within specified timeframes. Any discretionary spending (spending subject to annual congressional appropriations) related to those reporting requirements would be less than $500,000 over the 2026–2031 period. Direct spending (mandatory spending not subject to annual appropriations) by agencies that use fees or other collections to fund operations could change slightly, but CBO estimates that effect would be negligible because those agencies can adjust their collections to offset cost changes. The bill contains no intergovernmental or private-sector mandates.
How implementation would work
Within 180 days of enactment, the OMB Director would issue guidance to executive agency heads that instructs contracting officers how to document and review each use of an education requirement and encourages them to adopt alternatives. The prohibition itself would not take effect until 15 months after enactment, giving agencies time to update solicitation templates and internal procedures. A separate provision would repeal an older statute (Section 813 of the Floyd D. Spence NDAA for FY2001) once the OMB guidance takes effect. The GAO would assess agency compliance and report to Congress three years after enactment.
Legislative status & sources
Latest action
Received in the Senate and Read twice and referred to the Committee on Homeland Security and Governmental Affairs.
Official CRS summary
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This bill prohibits federal contract bid solicitations for contractor personnel from including minimum educational requirements unless the contracting officer justifies the requirements. The prohibition applies to educational requirements that may be met through education alone, education or experience, or a combination of education and experience.
The bill also requires the Office of Management and Budget to issue implementing guidance to federal agencies, including instructions for contracting officers that encourage using alternatives to education requirements.
Legislative subjects
Congressional oversight; Government Operations and Politics; Government information and archives; Public contracts and procurement