Preparing for the Open Enrollment Surge: HealthCare.gov, FEHB, and the November Peak

Prepare for the Open Enrollment surge with strategies for federal contact center staffing, bilingual coverage, workforce readiness and peak demand.

The Open Enrollment surge begins November 1 with HealthCare.gov, followed days later by Federal Benefits Open Season. These overlapping enrollment periods bring millions of people into the process of reviewing coverage, comparing options, completing enrollment actions, and seeking assistance.

The workforce problem starts well before the first spike in calls. By November, agents need to be trained, systems-ready, scheduled, and supported. A staffing plan that is still trying to build capacity once demand arrives is already behind.

For prime contractors, the question is therefore not how many seasonal agents can be hired. It is how much productive capacity will actually be available when Open Enrollment reaches its peak.

Why November Creates a Federal Contact Center Capacity Problem

HealthCare.gov and Federal Benefits Open Season serve different populations, but their enrollment calendars overlap.

HealthCare.gov’s Open Enrollment Period for 2027 coverage begins November 1, 2026. The standard Marketplace window runs through January 15.¹

Federal Benefits Open Season operates on a shorter schedule. OPM sets the annual period from the Monday of the second full workweek in November through the Monday of the second full workweek in December. In 2026, that places the window from November 9 through December 14.²

For contact center operations, those dates matter because the demand is concentrated.

Marketplace consumers may be starting applications, comparing plans, updating household information, checking financial assistance, submitting documents, or trying to resolve an enrollment issue before an effective-date deadline.

Federal employees and eligible participants may simultaneously be reviewing FEHB options and making benefits decisions during their own annual enrollment window.

The programs do not share one contact center or one operating model, but they do create overlapping demand for similar workforce capabilities: healthcare customer service experience, process accuracy, strong communication, familiarity with sensitive information, and the ability to work through complex questions without creating additional confusion.

That can tighten the labor market precisely when contractors need the largest number of trained people available.

How Many Agents Does HealthCare.gov Use During Open Enrollment?

There is no current public CMS figure showing the exact number of agents supporting the Marketplace Call Center for the 2027 enrollment season.

There is, however, useful historical context.

CMS reported that Marketplace Call Center staffing peaked at approximately 10,000 people during the Open Enrollment period preceding the 2019 plan year and that it intended to maintain that staffing level for the following enrollment season.³

The figure should be treated as historical rather than as today’s staffing level, but it shows the scale federal enrollment support has required before.

The customer population remains substantial. During the 2026 Marketplace Open Enrollment Period, nearly 23 million consumers selected or were automatically re-enrolled in coverage through the federal and state Marketplaces. Approximately 15.8 million of those plan selections were through HealthCare.gov.⁴

CMS has also previously described its call center as a front line for consumers applying for coverage and comparing plans, and has documented the use of extensive pre-Open Enrollment training and refresher training during the enrollment period.³

That is the part workforce planners should pay attention to.

Ten thousand names on a staffing roster would mean very little if the operation could not turn them into productive capacity.

The same principle applies at any scale.

A surge plan has to account for every step between identifying a candidate and having an agent independently handling live contacts. Recruiting, screening, onboarding, systems access, training, nesting, and early QA all consume time and capacity before the workforce can absorb volume.

How Far in Advance Should Open Enrollment Contact Center Hiring Begin?

There is no federal rule that says Open Enrollment recruiting must begin a specific number of weeks before November.

The more useful calculation works backward from the date agents need to be productive.

If a program requires several weeks of training, system access, background screening, nesting, or healthcare-specific learning, those steps need to be completed before peak demand arrives. Recruiting has to begin early enough to absorb those lead times as well as the candidates who accept an offer but never reach production.

That makes the final four weeks before Open Enrollment a poor time to begin building the primary workforce.

By then, program leaders should be validating readiness.

How many agents have accepted?
How many have actually started?
How many are through training?
How many are in nesting?
How many can independently take contacts?
Where are the remaining gaps?
What does the replacement pipeline look like?

The difference between hired headcount and productive headcount becomes critical during a fixed enrollment window.

Bilingual Open Enrollment Staffing Needs Its Own Capacity Plan

Language support adds another layer to Open Enrollment workforce planning.

HealthCare.gov provides Spanish-language services and makes language assistance available through the Marketplace Call Center. Consumers who need help in languages other than English can also request interpreter assistance at no cost.

For staffing purposes, bilingual capacity should not disappear inside the overall headcount number.

A program can reach its total staffing target and still enter Open Enrollment short of the language capability required by its customer population.

Spanish-language demand can place particular pressure on a smaller pool of bilingual employees. If that pool is too thin, those agents have less room for schedule changes, coaching, absence coverage, or unexpected increases in contact volume.

Recruiting bilingual agents also requires more than confirming that someone speaks Spanish conversationally.

Healthcare support requires agents to communicate accurately while discussing coverage, applications, eligibility information, documentation, and next steps. Language proficiency needs to hold up inside the actual context of the role.

That makes bilingual staffing part of the initial workforce forecast.

It should have its own sourcing targets, readiness numbers, schedule coverage, replacement pipeline, and quality monitoring.

Four Surge Staffing Models for Open Enrollment Contact Centers

Open Enrollment programs do not all need the same workforce structure.

The right model depends on the size and length of the volume increase, training complexity, existing workforce capacity, bilingual requirements, and what happens to additional employees when demand falls.

Four models are particularly useful for federal contact center planning.

1. Core Workforce With a Seasonal Overlay

A permanent workforce continues to manage baseline demand while additional agents are hired for the enrollment period.

This gives the program an experienced operational core while allowing headcount to expand around a predictable peak.

The pressure point is support capacity.

A large seasonal class creates additional work for trainers, supervisors, QA teams, schedulers, and escalation resources. Programs that expand frontline headcount without expanding those functions can create a bottleneck behind the agents.

2. Staged Training and Deployment

Instead of trying to recruit and train the entire surge population at once, the workforce enters in planned cohorts.

One group may be nesting while the next is in training and another is completing onboarding.

This gives the program more control over throughput and allows early lessons to improve later classes. It also spreads demand across trainers and supervisors rather than placing the entire ramp on one start date.

For a long enrollment window, staged deployment can also position additional capacity closer to later deadlines rather than requiring every surge agent to be production-ready on November 1.

3. Cross-Trained Workforce Redeployment

Some contractors may have employees elsewhere in the organization who can temporarily support enrollment work, provided the contract, training requirements, systems access, and employee qualifications allow it.

The advantage is access to workers who already understand the contractor’s operating environment.

The limitation is readiness.

Moving an experienced contact center agent from another program does not automatically make that person ready for federal healthcare enrollment work. Program knowledge, systems training, security requirements, and customer-specific processes still need to be addressed.

Redeployment works best when it has been planned in advance rather than used as an emergency response to missed staffing targets.

4. Core, Seasonal, and Backfill Capacity

This model builds three layers into the workforce plan.

The core team provides stability. A planned seasonal cohort expands capacity for expected demand. A separate backfill pipeline remains active to replace early attrition, failed starts, unexpected absences, or higher-than-forecast volume.

That third layer matters because surge recruiting rarely ends when the target headcount is reached.

If the entire pipeline closes once training begins, every early loss reduces the program’s available capacity.

A backfill strategy keeps the workforce plan moving while the surge is already underway.

What Separates Open Enrollment Programs That Hold Service Levels?

The programs that enter November in the strongest position have usually solved more than recruiting.

They know their productive headcount, rather than relying on offers accepted.

They have enough training capacity to move candidates through the program without creating a queue before the real queue even begins.

Supervisor ratios account for the fact that a large proportion of the workforce may be newly trained.

QA capacity expands alongside frontline staffing so that speed does not come at the expense of accuracy.

Bilingual coverage has been forecast independently.

The recruiting pipeline remains active after the first classes start.

Most importantly, the workforce plan has been tested against something other than the expected forecast.

What happens if volume arrives earlier?
What happens if the first training class loses more people than expected?
What happens if absenteeism increases during the busiest week?
What happens if Spanish-language demand exceeds the original model?
What happens if additional capacity is needed seven days from now?

A surge plan becomes useful when it can answer those questions before the program needs the answers.

What Primes Should Ask a Workforce Partner Four Weeks Before Open Enrollment

Four weeks before Open Enrollment, a staffing partner should be able to talk about readiness in operational terms.

A prime should know:

How many production-ready agents will we have by the required date?

Candidate pipeline numbers are useful, but they should be separated into sourced, interviewed, offered, accepted, started, training, nesting, and production-ready populations.

Where are we losing people before production?

Fallout should be visible early enough to trigger additional recruiting rather than becoming a surprise at the end of training.

What does bilingual readiness look like?

Total agent capacity and Spanish-language capacity should be reported separately where bilingual support is required.

How quickly can we replace a lost agent?

The answer reveals whether the staffing provider still has pipeline depth after the initial ramp.

What happens if the forecast is wrong?

The staffing model should identify how additional capacity can be sourced, trained, and deployed if demand exceeds expectations.

What workforce support does the surge require?

More agents can mean more trainers, supervisors, quality analysts, schedulers, and escalation support. The prime needs visibility into the operating model around the new hires, not only the hiring number.

What is the ramp-down plan?

The surge does not end operationally the moment volume falls. Workforce decisions after the peak can affect retention, morale, final service levels, and the contractor’s ability to respond to late enrollment activity.

These are the questions that reveal whether a workforce partner is supplying seasonal labor or managing surge capacity.

How Open Enrollment Surge Performance Can Affect CPARS

Open Enrollment may be seasonal, but the contractor’s performance during the surge still becomes part of the wider contract record.

FAR 42.1501 identifies past performance information as including a contractor’s record of conforming to requirements, controlling costs, adhering to schedules, behaving reasonably and cooperatively, and demonstrating concern for the customer’s interests.5

FAR 42.1503 requires evaluations to address factors including technical or service quality, schedule or timeliness, management or business relations, and other applicable performance areas. Evaluations should reflect objective facts supported by contract and program performance data.6

For a contact center contractor, the Open Enrollment period can generate plenty of that data.

Staffing shortages may show up in service levels.

A rushed ramp may affect quality.

High early attrition may create schedule or coverage problems.

Weak workforce forecasting may require repeated recovery actions.

A well-managed surge can demonstrate the opposite: the contractor forecasted demand, brought capacity online when required, responded to workforce changes, and protected service during the program’s most demanding period.

That is why Open Enrollment staffing belongs in the performance strategy for the contract.

The hiring plan is only one part of it.

How Salem Solutions Supports Open Enrollment Contact Center Staffing

Salem Solutions approaches Open Enrollment as a workforce capacity challenge that starts before seasonal hiring begins.

That means building pipeline depth around the required production date, sourcing for healthcare contact center and bilingual needs, planning staged deployment, maintaining backfill capacity, and helping federal contractors respond when actual workforce requirements move beyond the original forecast.

For primes supporting federal healthcare programs, the objective is straightforward: enter November with enough trained capacity to absorb the peak without sacrificing the people, supervision, and service quality needed to perform through the full enrollment window.

Preparing for the Open Enrollment surge? Talk to us about building the workforce capacity behind your federal healthcare contact center.

References

HealthCare.gov, “Get or Change Coverage Outside of Open Enrollment,” Centers for Medicare & Medicaid Services, accessed September 2026, https://www.healthcare.gov/coverage-outside-open-enrollment/.
U.S. Office of Personnel Management, “What Is Open Season?” accessed September 2026, https://www.opm.gov/frequently-asked-questions/insure-faq/health/what-is-open-season/.
Centers for Medicare & Medicaid Services, “Federal Health Insurance Exchange 2019 Open Enrollment,” October 11, 2018, https://www.cms.gov/newsroom/fact-sheets/federal-health-insurance-exchange-2019-open-enrollment.
Centers for Medicare & Medicaid Services, “Marketplace 2026 Open Enrollment Period Report: National Snapshot,” January 28, 2026, https://www.cms.gov/newsroom/fact-sheets/marketplace-2026-open-enrollment-period-report-national-snapshot-2.
Federal Acquisition Regulation, “42.1501 General,” Acquisition.gov, effective March 13, 2026, https://www.acquisition.gov/far/42.1501.
Federal Acquisition Regulation, “42.1503 Procedures,” Acquisition.gov, effective March 13, 2026, https://www.acquisition.gov/far/42.1503.

Government Shutdown Resilience for Contact Center Contractors

A government shutdown can disrupt federal contractors in different ways. Learn how contact center contractors can protect workforce and service continuity.

A government shutdown does not produce the same outcome for every federal contact center contract.

One program may continue operating because funding was already obligated. Another may receive a stop-work order. A third may continue only the portion of its work necessary to support an excepted government function.

For contractors, that uncertainty creates a different operational problem: decisions about staffing, payroll, subcontractors, and service continuity often have to be made before anyone knows how long the lapse will last.

The strongest shutdown contingency plans are therefore built before appropriations expire.

This article breaks down what happens to federal contractors during a government shutdown, how funding and excepted activities affect contact center operations, and what contractors should have in place before a lapse begins.

What Happens to Federal Contractors During a Government Shutdown?

A lapse in appropriations does not automatically cancel existing federal contracts.

The first question is whether funds have already been legally obligated to the work.

OMB guidance recognizes that activities financed by resources that remain available, including carryover balances, multi-year or no-year funding, may continue during a lapse.¹ Historical Department of Justice shutdown guidance has similarly explained that work under a contract funded before the lapse may continue when performance does not depend on furloughed federal employees or require additional funding.²

That distinction matters enormously for federal contact centers.

A contractor supporting a fully funded period of performance may have authority and funding to continue work even while other functions inside the agency shut down.

An incrementally funded contract carries a different exposure.

Under FAR 52.232-22, which applies to incrementally funded cost-reimbursement contracts, the contractor performs only up to the amount currently allotted. The Government is not obligated to reimburse costs beyond that amount unless additional funding is formally provided.³

In other words, the contract ceiling and the amount currently funded are not necessarily the same thing.

For contact center operators approaching September 30, the important number is not simply total contract value. It is how much funding is actually obligated, which work that funding covers, and how long the available amount can sustain performance.

That needs to be known before a lapse begins.

How Funding Status Affects Federal Contract Performance During a Shutdown

Funding is only one dependency.

A funded contractor may still depend on federal employees for approvals, supervision, system administration, security access, escalations, policy interpretation, or other actions required to perform the work.

That creates an important shutdown scenario.

The money may be available, but the operating environment may not be.

DOJ shutdown guidance has previously instructed that a pre-funded contract could continue when contractor performance did not require furloughed federal personnel. Where federal employee supervision or interaction was necessary and those activities could not continue, the agency could suspend contractor performance.²

For a contact center, that means contingency planning needs to map government dependencies as closely as workforce dependencies.

Which federal personnel does the program need every day?

Who approves escalated cases?

Who maintains system access?

Who can authorize policy changes?

Which government counterparts will remain available during a lapse?

What happens if a contact center agent receives a case requiring agency intervention while the responsible government team is furloughed?

These are operational questions that should be answered before the appropriations deadline, not discovered during the first morning of a shutdown.

What Are Excepted Services During a Federal Government Shutdown?

Shutdown terminology can create unnecessary confusion.

Under the Antideficiency Act framework, certain government activities may continue during a lapse because they are funded from available sources or fall within recognized exceptions. These can include activities expressly authorized by law, activities necessarily implied by other authorized functions, certain constitutional duties, and work necessary to protect human life or government property.¹

OMB requires agencies to maintain contingency plans identifying which activities will continue and which will cease during a lapse.¹

For contractors, however, the question is more specific than whether an agency performs “excepted work.”

A contact center may support an agency function that continues during the shutdown, but the contractor still needs to know:

whether its contract has available funding
whether contractor support is required for the continuing activity
whether necessary federal oversight will remain available
whether systems and facilities will remain accessible
whether the Contracting Officer has directed performance to continue

A federal contact center therefore should not make its own assumption that service is either excepted or non-excepted based solely on the mission of the agency.

The contract, available appropriations, agency contingency plan, and written direction from authorized government personnel determine what happens next.

What Is a Stop-Work Order in Federal Contracting?

If an agency determines that contract performance should stop, the Contracting Officer may issue a stop-work order where the applicable contract clause provides for it.

FAR 52.242-15 permits the Contracting Officer to require the contractor to stop all or part of the work covered by the order. Once the order is received, the contractor must comply and take reasonable steps to minimize costs associated with the stopped work.⁴

For a labor-intensive contact center, that instruction creates an immediate financial decision.

Agents may already be scheduled.

Payroll obligations may be approaching.

Supervisors, trainers, quality personnel, workforce planners, and subcontracted staff may all be attached to the program.

The contractor cannot simply continue performing in the hope that the Government will eventually pay for the work.

At the same time, immediately releasing trained personnel creates another risk. If appropriations return several days later, the contractor may be expected to restart operations quickly without knowing how many people will return.

A strong stop-work response therefore has two jobs:

control costs now and protect restart capacity later.

FAR 52.242-15 also provides a mechanism for an equitable adjustment when a stop-work order is canceled and it has increased the time or cost required for performance, subject to the contract terms and notice requirements. The clause generally requires the contractor to assert its right to an adjustment within 30 days after the stoppage ends.⁴

That makes contemporaneous documentation essential.

How Government Shutdowns Affect Contractor Payroll and Cash Flow

Federal employees affected by a lapse have statutory protection for retroactive pay under the Government Employee Fair Treatment Act of 2019. The law applies to employees of the United States Government and certain District of Columbia employees.⁵

Contractor employees do not have equivalent automatic protection.

The Professional Services Council’s 2025 shutdown guidance states plainly that no federal law guarantees shutdown-related back pay for contractor employees once appropriations are restored.⁶

For contact center contractors, that makes payroll runway part of continuity planning.

Before September 30, leadership should already understand the cost of several scenarios:

Three to five business days of disruption. Can payroll continue while the contractor waits for clearer direction?

Two weeks. Which workforce costs can the business absorb without reimbursement certainty?

Thirty days or longer. What retention decisions become necessary, and how would they affect restart?

The answer will differ by contractor, contract type, workforce size, and funding position.

What matters is that the decision has been modeled before the company is forced to make it under pressure.

Payroll planning should also distinguish between employees who continue performing funded work, employees whose work is stopped, and personnel who could potentially be redeployed temporarily.

Without that separation, the contractor risks making one workforce decision for employees facing very different contractual circumstances.

Workforce Contingency Planning for Federal Contact Center Contractors

The immediate temptation during a shutdown is to focus entirely on cost reduction.

For contact center programs, that can create a second problem when the shutdown ends.

A trained agent is not an interchangeable seat.

Employees may hold agency-specific knowledge, completed background checks, system credentials, specialized program training, or experience handling complex customer populations.

If those employees leave during an extended lapse, restarting the contract may require recruiting, onboarding, credentialing, and retraining before the contact center can return to its previous capacity.

Contractors therefore need a workforce contingency plan with more than one option.

Some employees may remain fully active because their work continues.

Others may move temporarily to another funded program where contractual and employment requirements permit.

Some may need reduced schedules or furloughs.

Critical supervisors, trainers, or specialized personnel may warrant a different retention strategy because losing them would materially slow restart.

The objective is to understand which workforce capabilities would be hardest to rebuild.

That analysis is particularly important for programs requiring specialized experience, public trust determinations, suitability requirements, or agency-specific systems knowledge.

A shutdown may last days. Reconstructing the workforce it disrupted can take considerably longer.

How Federal Contractors Should Manage Subcontractors During a Shutdown

Prime contractors cannot build shutdown resilience only around their direct workforce.

If subcontractors provide agents, recruiting support, training, technology, quality assurance, or other operational capacity, uncertainty flows downstream quickly.

Subcontractors need clear direction on:

whether work should continue
which tasks are affected
when costs should stop accruing
what documentation must be maintained
which personnel should remain available
how restart communications will work

The prime also needs visibility into subcontractor decisions that could affect continuity.

If a staffing subcontractor furloughs an entire workforce on day one, the prime needs to know what that means for restart capacity.

If personnel are redeployed elsewhere, how quickly can they return?

If a subcontractor continues incurring costs without clear authorization, who carries that exposure?

Shutdown planning therefore needs a communications path that reaches every organization responsible for contract performance, not simply the prime’s internal management team.

How to Document Shutdown Costs for Potential Cost Recovery

Shutdown conditions move quickly, which makes documentation easy to postpone.

That is a mistake.

If a contractor later seeks an equitable adjustment or other allowable recovery associated with a stop-work order, it needs evidence connecting the disruption to the resulting cost or schedule impact.

FAR 52.242-15 specifically requires contractors receiving a stop-work order to minimize costs allocable to the stopped work and establishes conditions for adjustments after work resumes.⁴

Contractors should therefore maintain a shutdown record from the first notice through restart.

That record should capture:

written direction from the Contracting Officer
dates and times when work stopped or changed
affected contract line items or functions
staffing actions taken
payroll and benefit costs
subcontractor instructions and responses
costs incurred to preserve the workforce
canceled or postponed training
system or facility access interruptions
restart costs
schedule or performance impacts
steps taken to mitigate additional expense

Informal conversations can help teams operate, but contractual direction should be documented through the appropriate government channels.

The shutdown file should make it possible to reconstruct what happened without relying on memory weeks or months later.

What Should Be Included in a Federal Contractor Shutdown Contingency Plan?

A useful shutdown plan should answer operational questions before appropriations become uncertain.

Funding and Obligated Contract Value

What amount is currently obligated, and what period of performance or work does it support?

Government Personnel and System Dependencies

Which agency employees, systems, facilities, and approvals are necessary to continue service?

Stop-Work and Continuation Authority

Who is authorized to tell the contractor to continue, reduce, or stop performance?

Workforce Retention and Redeployment

Which employees would continue working, which could be redeployed, and which positions are most important to retain for restart?

Payroll Runway and Cash Flow

How long can the contractor maintain different workforce scenarios without assuming reimbursement that has not been authorized?

Subcontractor Communication

What instructions and reporting requirements will flow downstream?

Cost and Performance Documentation

Who owns the record of shutdown-related direction, costs, workforce changes, and operational impacts?

Restart and Workforce Recovery

How quickly can the program return to normal staffing and service levels once appropriations resume?

That last question deserves as much attention as the shutdown itself.

Continuity planning is successful when the program can absorb the interruption without losing the workforce, knowledge, or operating capacity it needs when the government reopens.

How Salem Solutions Supports Government Shutdown Workforce Continuity

Salem Solutions helps federal contact center contractors build workforce models that can respond when operating conditions change quickly. That includes maintaining candidate pipeline depth, supporting rapid backfill, planning for surge and redeployment needs, and protecting workforce continuity when programs move between full operations, reduced activity, and restart.

For prime contractors, appropriations uncertainty is easier to manage when the workforce plan already accounts for who must stay, where staffing can flex, and how quickly capacity can be restored.

Preparing your federal contact center workforce for FY27? Talk to us about building a continuity and restart staffing plan before you need it.

References

Office of Management and Budget, “Section 124: Agency Operations in the Absence of Appropriations,” OMB Circular No. A-11, 2025, https://www.whitehouse.gov/wp-content/uploads/2025/08/a11.pdf.
U.S. Department of Justice, “Lapse in Appropriations Reference Guide,” Justice Management Division, accessed August 2026, https://www.justice.gov/doj/page/file/779511/dl?inline=.
Federal Acquisition Regulation, “52.232-22 Limitation of Funds,” Acquisition.gov, effective March 13, 2026, https://www.acquisition.gov/far/52.232-22.
Federal Acquisition Regulation, “52.242-15 Stop-Work Order,” Acquisition.gov, effective March 13, 2026, https://www.acquisition.gov/far/52.242-15.
U.S. Department of Justice, “Government Employee Fair Treatment Act of 2019,” January 2019, https://www.justice.gov/doj/page/file/1124746/dl.
Professional Services Council, “Government Shutdown Fact Sheet,” updated November 12, 2025, https://www.pscouncil.org/a/Resources/2025/Shutdown_2025/Government_Shutdown_Fact_Sheet.aspx.

The Post-Award Transition Playbook for Federal Contact Centers

Federal contact centers face major workforce and performance risks after award. Learn what a strong 30/60/90-day transition plan should cover.

Federal contact center transitions compress staffing, credentialing, knowledge transfer, systems access, and performance readiness into a very short window.

That makes the first 90 days after award one of the highest-risk periods in the contract lifecycle. The incoming contractor is not simply building a team. It is taking responsibility for an operation that may already be serving citizens, operating under SLA obligations, and relying on institutional knowledge that could leave with the incumbent workforce.

FAR 52.237-3 allows the government to require phase-in and phase-out support for up to 90 days when continuity of vital services is at stake.

This article breaks down what a federal contract transition plan needs to accomplish from award through day 90, where the biggest risks appear, and how contractors can move from handover to stable operations without losing control of performance.

Before Day One: The Transition Has Already Started

A transition plan cannot begin on the first day of performance.

By then, several of the decisions that will determine day-one readiness should already be moving.

The incoming contractor needs to understand the staffing requirement by role, shift, location, clearance or suitability level, language capability, supervisory structure, and anticipated demand. It needs visibility into which incumbent employees may be available, which positions require external recruitment, and which individuals can realistically complete onboarding and access requirements before go-live.

The outgoing contractor may also have formal transition obligations.

Where FAR 52.237-3 is included in the contract, the incumbent can be required to cooperate with the successor, provide phase-in training, negotiate a transition plan after written notice from the Contracting Officer, maintain sufficient experienced personnel during the agreed phase-in and phase-out period, and allow the successor to interview incumbent personnel.¹

That does not mean every incumbent employee automatically transfers.

The regulatory environment around incumbent retention also changed significantly in 2025. Executive Order 14055, which had required a right of first refusal for qualified workers on many successor federal service contracts, was revoked in January 2025. The Department of Labor formally rescinded its implementing regulation in December 2025.²

For contractors entering a transition today, incumbent retention therefore depends on the applicable contract terms, agency requirements, employee decisions, labor obligations where relevant, and the successor’s workforce strategy.

Operationally, however, the value of incumbent experience has not disappeared simply because the regulatory requirement changed.

Experienced agents may already understand the program’s systems, terminology, escalation paths, seasonal demand patterns, knowledge base, and customer population. Losing too much of that experience at once forces the incoming contractor to rebuild operational knowledge while simultaneously trying to perform.

That is a difficult way to start a federal contract.

Days 1 to 30: Protect Continuity Before You Chase Optimization

The first 30 days are about controlling exposure.

The workforce roster may look complete on a transition spreadsheet while a significant portion of that workforce is still waiting for credentials, equipment, system permissions, final training, or access to the tools required to do the job.

Federal credentialing is one reason headcount and productive headcount cannot be treated as the same number.

HSPD-12 requires identity credentialing for federal employees and contractor personnel who need routine physical access to federally controlled facilities or logical access to federal information systems. GSA’s current HSPD-12 guidance also links contractor access to background investigations, identity verification, and Personal Identity Verification credentials.³

A person who has accepted an offer but cannot access the environment does not solve the operational requirement.

The transition plan therefore needs to track readiness at the individual level:

employment accepted
required screening completed
suitability or credentialing actions initiated
equipment issued
system access approved
training completed
nesting status
production readiness

That distinction becomes particularly important during high-volume transitions. If leadership only monitors recruiting totals, a program can appear fully staffed right until the day access delays expose the real capacity gap.

Knowledge Capture Has to Happen While the Knowledge Is Still Available

The other early priority is knowledge transfer.

Contact center transition documents usually capture formal processes well. The harder information to replace sits between the documented steps.

Which inquiries routinely create confusion? Which knowledge articles require explanation before a new agent understands them? Where do escalations stall? Which cases look straightforward but usually need supervisor intervention? What changes during seasonal or policy-driven surges?

That knowledge often sits with incumbent agents, supervisors, trainers, and quality personnel.

FAR 52.237-3 specifically anticipates phase-in training and a planned transfer of responsibilities where the clause applies. For a contact center, that period should be used to capture operational context as well as documented procedures.

The incoming contractor should leave the first 30 days with more than a collection of SOPs. It should have a usable map of how the operation actually behaves.

Days 31 to 60: Move From Transition Staffing to Production Stability

By the second month, the question changes.

The program no longer needs to prove that people can be placed into seats. It needs to prove that the new operating model can sustain performance.

This is where nesting and parallel operations become important.

Newly trained agents need controlled exposure to live interactions, close supervisor support, and fast feedback. Incumbent or experienced personnel can provide valuable stability while newer staff move toward full proficiency.

The danger is accelerating this stage simply because the contractual start date has passed.

If too many new agents enter production simultaneously, quality scores can fall, escalations can increase, and supervisors can become overloaded. If experienced staff leave faster than replacements develop, the program loses precisely the people it needs to stabilize the transition.

The workforce plan should therefore look beyond headcount and begin tracking productive capacity.

That means watching indicators such as attendance, schedule adherence, quality, escalation volume, training completion, agent utilization, first-contact resolution where applicable, and the number of employees still requiring elevated support.

This Is Also When the Baseline Starts Becoming Useful

The first several weeks of a new contract generate data, but not all early data should immediately be treated as steady-state performance.

Transition conditions distort numbers.

Agents are learning, systems may still be stabilizing, processes are being corrected, and volumes may differ from the forecast used during capture.

By days 30 to 60, patterns become easier to separate from transition noise.

That is when program leadership can begin establishing a credible operating baseline and asking better questions.

Where is staffing consistently below requirement? Which shifts are carrying the most risk? What issues are generating repeat contacts? Where are supervisors spending disproportionate time? Which QA findings point to an individual coaching need, and which indicate a broader process problem?

The objective is not to defend every imperfect number produced during transition.

It is to show that the contractor understands what the numbers mean and is controlling the trajectory.

Days 61 to 90: Prove That the Operating Model Can Hold

Day 90 should look different from day one.

The program should have moved beyond transition activity into a workforce and performance model that can hold under ordinary operating pressure.

That means vacancy management should be predictable. Backfill processes should be functioning. Supervisory capacity should match the actual needs of the workforce. Training and QA feedback loops should be established. Credentialing should no longer be managed as a collection of emergencies. Knowledge should sit inside the operation rather than with a handful of people who survived the handover.

This is also the point where weaknesses that looked temporary earlier, become harder to dismiss as transition issues.

Persistent absenteeism is now a workforce problem, repeated quality failures are now a performance problem, an unresolved access backlog is now affecting execution, or a supervisor overload is now a management capacity problem.

A transition plan has succeeded when those risks are either under control or visible early enough for corrective action.

The First 90 Days Are Already Building the CPARS Story

The first formal CPARS evaluation does not normally arrive at day 90.

Current CPARS guidance states that for contracts or orders with a period of performance longer than 365 days, the first interim evaluation must reflect at least the first 180 calendar days of actual performance and may cover up to the first 365 days.⁴ FAR 42.1502 requires qualifying past performance evaluations at least annually and at contract or order completion.⁵

But waiting until month six to think about CPARS would miss the point.

The first 90 days begin creating the performance record that later supports the evaluation.

Under FAR 42.1503, contractor assessments are based on objective facts and performance data and include areas such as technical or service quality, schedule or timeliness, management or business relations, and small business subcontracting where applicable.⁶

Transition execution touches several of those areas immediately.

Did the contractor mobilize when promised? Did staffing delays affect service? Were problems surfaced early or discovered by the government? Did management respond effectively? Did the program maintain quality while responsibility changed hands?

CPARS narratives are built from performance events. The transition period produces some of the earliest evidence available.

A contractor that documents staffing recovery, corrective actions, service stabilization, and government communication from the beginning is in a much stronger position than one trying to reconstruct that story months later.

Where Federal Contact Center Transitions Usually Break

Several transition risks deserve attention long before they become visible in formal performance reporting.

Incumbent attrition happens faster than replacement readiness. The contractor assumes experienced workers will stay, but retention decisions come late and external recruiting begins too slowly.

Credentialing is treated as onboarding administration. Hiring targets are met while productive capacity remains below plan because new staff cannot access the systems they need.

Knowledge transfer focuses on documents instead of operations. Procedures move across, but exception handling, escalation context, and experienced judgment leave with the incumbent team.

Training throughput becomes more important than proficiency. Employees are pushed into production to satisfy staffing numbers before they can operate independently.

The program overreacts to early metrics or ignores them completely. Transition data needs context, but repeated patterns need action.

Workforce contingency planning stops at go-live. Once the initial hiring push ends, the pipeline disappears even though early attrition, failed credentialing, attendance issues, and unexpected volume can immediately create new gaps.

Each risk has a different operational cause, but they converge in the same place: service continuity.

A Better 30/60/90-Day Federal Contract Transition Plan

A strong transition plan should become progressively less dependent on transition activity.

By day 30, leadership should know exactly who is available, who is productive, who is waiting on access, where knowledge-transfer gaps remain, and where staffing risk could affect service.

By day 60, the operation should be building a reliable performance baseline. Training should be converting into productive capacity, QA should be identifying patterns, and the contractor should have enough pipeline depth to replace early losses without reopening an emergency recruiting cycle.

By day 90, the operating model should be able to sustain itself. Workforce management, performance oversight, backfill, knowledge management, and government reporting should function as normal operations rather than transition work.

That is the real objective of the first 90 days.

The contractor is not simply reaching full staffing. It is removing transition as an explanation the program still needs.

How Salem Solutions Supports Federal Contact Center Transitions

Salem Solutions approaches federal contract transition staffing with the workforce risks of the entire phase-in period in view. That means identifying incumbent retention opportunities early, building external candidate pipelines alongside them, screening for clearance or credentialing requirements before they create avoidable delays, and maintaining backfill capacity as the initial workforce moves through onboarding and production.

For prime contractors taking over a federal contact center program, the strongest transition plans account for the people who may stay, the people who still need to be hired, and the people who may be lost before the operation reaches steady state.

Preparing for a federal contact center award, recompete, or incumbent transition? Talk to us about building the workforce plan behind your first 90 days.

References

Federal Acquisition Regulation, “52.237-3 Continuity of Services,” Acquisition.gov, effective March 13, 2026, https://www.acquisition.gov/far/52.237-3.
U.S. Department of Labor, “Final Rule: Nondisplacement of Qualified Workers under Service Contracts (Executive Order 14055),” Wage and Hour Division, updated December 22, 2025, https://www.dol.gov/agencies/whd/government-contracts/service-contracts/final-rule-nondisplacement.
U.S. General Services Administration, “Homeland Security Presidential Directive-12, Personal Identity Verification and Credentialing, and Background Investigations for Contractors,” GSA Order 2181.1A ADM, March 27, 2024, https://www.gsa.gov/directives-library/homeland-security-presidential-directive12-personal-identity-verification-and-credentialing-and-background-investigations-for-contractors.
Contractor Performance Assessment Reporting System, “CPARS Guidance,” Section 5.2, accessed August 2026, https://www.cpars.gov/cparsweb/assets/documents/CPARS-Guidance.pdf.
Federal Acquisition Regulation, “42.1502 Policy,” Acquisition.gov, effective March 13, 2026, https://www.acquisition.gov/far/42.1502.
Federal Acquisition Regulation, “42.1503 Procedures,” Acquisition.gov, effective March 13, 2026, https://www.acquisition.gov/far/42.1503.

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References

The Post-Award Transition Playbook for Federal Contact Centers

Before Day One: The Transition Has Already Started

Days 1 to 30: Protect Continuity Before You Chase Optimization

Knowledge Capture Has to Happen While the Knowledge Is Still Available

Days 31 to 60: Move From Transition Staffing to Production Stability

This Is Also When the Baseline Starts Becoming Useful

Days 61 to 90: Prove That the Operating Model Can Hold

The First 90 Days Are Already Building the CPARS Story

Where Federal Contact Center Transitions Usually Break

A Better 30/60/90-Day Federal Contract Transition Plan

How Salem Solutions Supports Federal Contact Center Transitions

References

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