The federal government runs more than 229 known contract writing systems, according to a March 13, 2026, GSA blog post by Laura Stanton, Deputy Commissioner of the Federal Acquisition Service. GSA describes a fragmented landscape that produces siloed data, inconsistent processes and higher costs to modernize and maintain systems. In March 2026, the Office of Management and Budget pre-designated GSA to establish a governmentwide Acquisition Shared Services and Solutions Quality Service Management Office, known as the Acquisition QSMO, and GSA said it aims for formal designation later in the year.
For a chief procurement officer already managing more than one contract writing system, the announcement raises a practical question about which systems survive the transition. It also raises a harder one: what the surviving system will be expected to prove each time an obligation is recorded. Earlier shared-services efforts asked agencies to move to common platforms. This one arrives alongside executive orders that change what those platforms must enforce.
What changed: the enforcement environment
Executive Order 14402, signed April 30, 2026, makes fixed-price, performance-based contracting the default method of federal procurement to the maximum extent consistent with law. That shift raises the stakes for obligation controls. Cost-reimbursement contracts pay against costs documented as work proceeds, which leaves room to assemble the record along the way. Fixed-price contracts pay for a defined outcome, so the agreement has to be in place when the obligation is recorded and delivery has to be verified before payment is released. The obligation gate becomes a precondition, not an audit item.
Executive Order 14249, signed March 25, 2025, adds a second layer by directing pre-payment screening and expanding use of Treasury’s Do Not Pay system. Together, the two orders define what a properly utilized contract writing system has to do: confirm the agreement before the obligation, and confirm the outcome before the payment.
What has always been required
Federal law has always required a binding written agreement before any obligation is recorded. The problem with more than 229 systems is not that agencies have the wrong systems. It is that more than 229 systems have found as many different ways to accept an obligation entry without one.
Consolidation is the vehicle, utilization is the destination.
None of this argues against consolidation. Fewer systems mean fewer places for inconsistent practice, cleaner data for oversight and lower costs to maintain. GSA’s stated goals for the Acquisition QSMO include common business and data standards for acquisition systems. The distinction is between the number of systems and the controls each one enforces. A consolidated system that accepts an obligation entry without a binding agreement carries the old problem into fewer places.
As agencies evaluate transition pathways, four questions separate consolidation from utilization:
- Does the system require a binding written agreement before it records an obligation?
- Does it tie payment release to verified delivery against the terms of that agreement?
- Does it carry pre-payment screening results forward before funds are disbursed?
- Does the supporting evidence stay attached to the obligation record, where an auditor can find it?
Reducing more than 229 systems to a manageable number of pre-vetted solutions is a necessary conversation. But the law does not ask how many systems an agency uses to record obligations. It asks whether each obligation is supported by a binding written agreement at the moment it is recorded. That question does not get easier with fewer systems. It gets more visible.
To learn how Actus addresses this challenge, contact Heidi Egusquiza at heidi@paperless-innovations.com.
Paperless Innovations Inc is FedRAMP® Moderate Authorized and holds Treasury FM QSMO First Source designation under SIN 518210FM on GSA Multiple Award Schedule Contract #47QTCA24D002X. Actus is currently deployed at the Department of Homeland Security.
About Paperless Innovations Inc
Paperless Innovations Inc, based in Johns Island, South Carolina, builds the Actus Assured Acquisition and Payment Integrity Suite, the tokenized four-way match platform that verifies federal obligations and payments before funds move, through domestic software development conducted on-shore by a U.S.-based team. The company holds patent-pending status across nine provisional applications for its SmartPayNow™ two-phase gated token. More at act.us.
Media Contact
Heidi Egusquiza, Vice President of Public Sector, Paperless Innovations Inc
heidi@paperless-innovations.com | 888-522-6255