BABA Domestic Content Compliance Engine (OriginVault)
Done-for-you Build America, Buy America (BABA) domestic-content documentation, manufacturer-certification chase, payment-package assembly, and waiver-packet prep for mid-market infrastructure contractors — not a customer-operated compliance co-pilot.
01 Thesis
Mid-market general contractors and specialty subcontractors on federally assisted infrastructure projects already lose progress payments, burn project-controls hours, and carry False Claims Act exposure when manufacturer BABA certifications are missing, generic, mis-categorized, or late. OriginVault sells the payment-ready BABA evidence package — product-classified SKU register, project-specific manufacturer certifications, mill-test / component-cost support where required, exception queue, and optional waiver packet — assembled by an internal AI engine and signed off by a domestic-content specialist. The customer experiences a compliance desk, not software.
Why AI-native: the work is document-heavy extraction, category classification under 2 CFR Part 184 / agency overlays, supplier chase orchestration, completeness scoring, and audit-trail packaging — exactly the pattern frontier models accelerate while humans remain at categorization edge-cases, waiver strategy, and customer-facing trust. Why not a co-pilot: primes and owners already withhold payment until the file is complete; they will not staff another portal.
02 Discovery rationale
Terrain scanned this hour: BABA/domestic content, EPCRA Tier II (already crowded with consultants), AES/EEI export filing (commoditized forwarder work), FTC Click-to-Cancel (federal rule vacated — softener), Section 45Q (narrow taxpayer set + licensed tax practice), LIHTC/HUD (prior HOTMA/LIHTC blueprints), OSHA ITA (prior), PFAS TSCA (prior + delayed start), CA pay data (H17 OFF-LIMITS).
- Decisive verified catalyst: FHWA Manufactured Products Final Rule (effective Mar 20, 2025) phases in US final-assembly for manufactured products on obligations on/after Oct 1, 2025 and the 55% domestic component-cost test on/after Oct 1, 2026 — expanding documentation burden beyond traditional iron/steel. Verified
- Budget proof: Big-4/advisory (Cherry Bekaert), sourcing consultants (Free Market America), and manufacturer-letter marketplaces already sell BABA help — category spend exists; mid-market DFY whitespace remains. Verified
- Payment pain: State CDBG / municipal specs explicitly withhold progress payments until BABA certifications are received. Verified
- Anti-dup: Distinct from IRA-PWA (payroll/apprenticeship for tax credits) and prevailing-wage certified payroll — different statute (BABA §§70901–27 / 2 CFR 184), inputs (manufacturer certs, mill tests, component-cost), buyer job (unlock payment / survive audit), adversary (agency payment hold + FCA on false domestic-origin claims).
03 Candidate comparison
| Candidate | Buyer | Outcome | Score /5 avg | Evidence | Decision |
|---|---|---|---|---|---|
| BABA Domestic Content Desk (OriginVault) | Mid-market GC / specialty sub on FHWA, EPA SRF, HUD CDBG, FEMA, DOE, BEAD jobs | Payment-ready BABA evidence package | 4.3 | High — statute, FHWA rule, payment-hold specs, advisory incumbents, FCA backdrop | WINNER |
| EPCRA Tier II Managed Filing | EHS managers, multi-site industrials | Accepted Tier II submission | 3.6 | High pricing/outsourcing proof (RMA $1.5–6k) but low intelligence threshold; crowded consultants; adjacent to prior TRI engine | Reject — commoditized annual form |
| AES/EEI Export Filing Desk | USPPIs / mid-market exporters | ITN before departure | 3.1 | Verified penalties & filing rules; but forwarders already fulfill; low judgment; weak Sam Altman | Reject — incumbent-commoditized |
| State Auto-Renewal / Click-to-Cancel Audit | Subscription SaaS / DTC brands | Cancellation-flow compliance pack | 2.4 | Federal 2024 rule vacated by 8th Cir (Jul 2025); ANPRM only — softener | Disqualified — unstable federal trigger |
| Section 45Q Form 8933 Evidence Pack | CCS project sponsors | Audit-ready sequestration credit file | 3.4 | Notice 2026-1 safe harbor real; tiny addressable set; CPA/tax-opinion heavy | Reject — narrow + licensing drag |
| Creditor Proof-of-Claim 9037 Monitor | Bankruptcy creditors / servicers | Filed claim + privacy-safe exhibits | 3.0 | Adjacent to FileMask (H16) — high dup risk | Reject — anti-dup |
04 Hard disqualifier check
| # | Disqualifier | Status | Notes |
|---|---|---|---|
| 1 | Customer-facing co-pilot / SaaS | Pass | Sells completed evidence package + cert chase; specialist is interface. |
| 2 | Substantial physical labor | Pass | Document/workflow only; no site crews (site visits optional later, not required). |
| 3 | Hourly primary pricing | Pass | Per-project package + per-SKU chase fees. |
| 4 | No path to 50%+ GM | Pass | High automation on extraction/chase; specialist minutes concentrated on exceptions. |
| 5 | Buyer unclear | Pass | GC project controls / compliance manager; owner/grantee as secondary. |
| 6 | Non-decomposable workflow | Pass | SKU list → classify → chase → validate → package → waive. |
| 7 | Fully automate regulated judgment | Pass | Specialist reviews category/waiver; counsel for FCA/legal opinions; client certifies pay apps. |
| 8 | Duplicative of prior blueprint | Pass | No prior BABA/domestic-content slug; distinct from IRA-PWA & certified payroll. |
| 9 | Illegal / unworkable licensing | Pass | No PE/attorney license required for documentation assembly; UPL avoided by not giving legal opinions. |
| 10 | Unverified core demand | Pass | Payment-hold specs + advisory product pages + FHWA rule = verified demand/budget. |
| 11 | Model progress commoditizes us | Pass | Models help; moat is supplier graph + agency templates + payment-package trust. |
| 12 | Cannot pilot small | Pass | One FHWA/SRF project, 50–200 SKUs, 30-day pilot. |
05 Rubric scorecard
Work already outsourced to advisors/consultants; buyers care about unlocked payment and audit file, not the tool.
Most steps = extract, classify, chase, completeness check; judgment at category edge-cases and waiver strategy.
Agency overlays, product classification, component-cost math, and waiver narratives beat offshore data entry.
Statutory BABA + 2 CFR 184 + agency rules + payment holds + FCA exposure.
Fully remote document/workflow service.
Better models → faster cert extraction, smarter chase, cheaper packages; supplier graph + agency playbooks compound.
Total gates: 26.5 / 30.
06 Opportunity
CODE
C — Consumer/buyer trend
FHWA manufactured-products waiver rescission + Oct 2025/2026 phase-in; multi-agency BABA flow-downs (EPA SRF, HUD, FEMA, DOE, BEAD).
O — Opportunity
Project teams lack a production system for product-specific, project-stamped manufacturer certifications and category-correct files.
D — Demand
Payment-withhold language in bid docs; Cherry Bekaert / Free Market America productized offers; contractor trade guidance urging dedicated BABA oversight.
E — Economics
Per-project fees $8k–$35k core; add-on per-SKU chase $75–$250; waiver packets $5k–$20k — outcome-priced against payment risk and rip-and-replace.
07 Evidence quality and source-claim matrix
| Claim | Label | Source | Conf. | Impact |
|---|---|---|---|---|
| BABA (IIJA §§70901–27) requires iron/steel, manufactured products, and construction materials on covered infrastructure FFA to be produced in the US unless waived | Verified | OMB M-24-02; 2 CFR Part 184 FR (Aug 23, 2023) | High | Core regulatory moat |
| 2 CFR Part 184 is primary OMB guidance; M-24-02 supplements and replaces M-22-11 | Verified | White House M-24-02 PDF | High | Rules layer design |
| FHWA Manufactured Products Final Rule effective Mar 20, 2025; final assembly for obligations ≥ Oct 1, 2025; 55% component cost ≥ Oct 1, 2026 | Verified | FHWA Q&A (updated Jan 5, 2026); 90 FR 2932 | High | Why-now catalyst |
| Manufacturer self-certification is the federal documentation model; letters must be product- and project-specific | Verified | US Made Supply BABA guide; agency sample cert practices | High | Defines deliverable |
| Some grantees withhold contractor payments until BABA certifications received | Verified | WI DEHCR BABA docs summary; Iowa/municipal specs | High | Buyer urgency / WTP |
| Advisory firms sell BABA assessment, cert chase, and documentation services | Verified | Cherry Bekaert BABA page; Free Market America | High | Budget validation |
| False domestic-origin / Buy America certifications can support FCA liability; FY2025 FCA recoveries >$6.8B; 1,297 qui tams | Verified | DOJ OPA FY2025 FCA release; Hinckley Allen; Law.com | High | Risk narrative (note: $6.8B is all-FCA, not BABA-only) |
| Mid-market contractors will pay $8k–$35k for DFY BABA packages | Inferred | Analog to advisory scopes + payment-hold cost of capital | Med | Pricing hypothesis — validate in pilots |
| Serviceable market ~$0.6B–$2.8B | Inferred | Contractor × project × fee model | Low–Med | Sizing only; not a go decision alone |
| Active LinkedIn/forum contractor complaints volume | Unverified | Not systematically sampled this run | Low | Do not rely; use payment-hold + vendor pages instead |
08 Why now
- Verified: FHWA manufactured-products phase-in (Oct 2025 assembly / Oct 2026 55%) expands cert burden beyond melt-and-pour steel culture.
- Verified: Multi-agency BABA implementation (HUD PIH 2025-06, EPA SRF, FEMA, DOE, BEAD self-cert lists) creates fragmented templates — a production engine wins on agency playbooks.
- Inferred: Frontier models now reliably extract fields from messy PDFs/emails and draft supplier chase sequences, collapsing COGS vs 2022-era manual desks.
- Unverified: Whether mid-market GCs will prefer contingency-free fixed packages over expanding internal project-controls headcount — must be tested in pilots.
09 Customer & PMF
| ICP | $25M–$400M revenue GC or specialty sub with ≥1 active federally assisted civil, water, broadband, or energy project; thin compliance staff. |
| Economic buyer | VP/Director of Project Controls, Compliance Manager, or CFO (payment risk). |
| User | Project engineer / PE admin / procurement lead who currently chases manufacturer letters. |
| Trigger | Notice to proceed; first pay app rejected for missing BABA docs; FHWA/SRF obligation after Oct 2025/2026 thresholds; owner audit notice. |
| Alternatives | Internal chase; big-4/advisory project; manufacturer marketplace; do-nothing until withhold. |
| JTBD | “Get every covered SKU certified project-specifically so my pay apps clear and my file survives audit — without hiring a BABA clerk.” |
| WTP evidence | Verified payment holds + verified paid advisory category; exact mid-market ASP inferred. |
10 The outcome we sell
Paid outcome: Payment-Ready BABA Evidence Package
- Deliverable: SKU register with BABA category (iron/steel, manufactured, construction material, excluded/de minimis); project-stamped manufacturer certifications on letterhead; supporting mill tests / assembly location / component-cost attestations as required; completeness score; exception log; optional waiver packet draft for owner submission.
- Acceptance: ≥98% of covered SKUs have category + cert or documented waiver/exception path; package formatted to owner/agency checklist; specialist sign-off memo.
- Promise: We assemble the evidence file and chase manufacturers; we do not guarantee agency payment timing or waive legal liability for client false certifications.
- Exclusions: Legal opinions on FCA exposure; PE stamps; on-site material testing; tax advice; Buy American Act (direct federal procurement) unless scoped as add-on.
- Rework: Free correction of our classification/packaging errors within 30 days; manufacturer non-response after N chase cycles billed as exception SKUs.
- Success metric: Pay-app documentation acceptance / owner checklist pass rate; days-to-complete-cert for median SKU.
ICP: Mid-market GC on FHWA or EPA SRF project · Trigger: NTP or first pay-app reject · Pain: Missing project-specific manufacturer certs · One-feature MVP: DFY manufacturer-cert chase + payment package for one project · Input: bid schedule / submittal log / POs · Output: cert vault + pay-app exhibit · Human chokepoint: domestic-content specialist category & completeness sign-off · Success: owner accepts package / pay app clears docs · Next ask: multi-project portfolio retainer + waiver desk + supplier pre-qualification graph.
11 Internal AI engine architecture
- Intake: Contract BABA clauses, funding agency, bid schedule, submittal register, POs, prior certs, SDS/cut sheets via secure upload / email.
- Normalization: SKU identity resolution, manufacturer aliases, unit costs, permanently-incorporated flags.
- Retrieval/knowledge: 2 CFR 184 definitions, FHWA 23 CFR 635.410 overlays, agency checklists (EPA/HUD/FEMA/DOE/BEAD), prior gold-standard letters, waiver templates.
- AI workbench: Extract product attributes; draft category hypothesis; generate manufacturer chase emails; parse returned letters; flag generic/non-project-specific language; draft waiver narratives.
- Deterministic rules: Threshold dates by obligation; iron/steel vs manufactured vs construction material classification tests; de minimis / excluded materials; required letter fields checklist.
- Human chokepoint: Specialist approves category edge-cases, accepts/rejects letters, escalates waiver strategy; counsel only if client requests legal opinion.
- QA: Dual completeness score; red-team sample of 5% SKUs; hash-versioned vault.
- Delivery: Owner-ready PDF/ZIP + pay-app exhibit index; portal link for client (view-only).
- Learning loop: Rejected letters → template library; agency comments → checklist updates.
- Model portability: Prompt/tooling abstracted; swap LLM providers without changing SOPs.
12 AI-vs-human operations pipeline
Ingest schedule/POs; extract SKUs
Apply agency date & category tests
Draft chase + parse cert PDFs
Manufacturer follow-ups / phone
Approve categories & letter quality
Signs pay-app certifications
13 Operations as product
Variance killed via: intake checklist (funding agency, obligation date, covered categories); required-evidence list per category; automated completeness gates before specialist review; exception queues (no-response manufacturer, ambiguous permanently-incorporated, multi-category kits); reviewer assignment by agency playbook; confidence scores on letter field extraction; audit trail of every chase; gold-standard letter corpus; red-team sampling; root-cause on pay-app rejects.
14 No-holes quality engine
- Reject generic “Made in USA” letters lacking project/product identity.
- Block delivery if obligation-date rule requires 55% component-cost attestation and letter omits it.
- Separate excluded materials / temporary items from covered permanently-incorporated items with explicit rationale.
- Never auto-file waivers to agencies — owner/grantee submits; we prepare packet only.
- Never coach client to certify known-false domestic content (FCA bright line).
15 Pricing, legality, and unit economics
Primary model: Fixed per-project BABA Evidence Package $8,000–$25,000 (≤150 SKUs) / $18,000–$35,000 (151–500 SKUs) + $75–$250 per additional SKU chase + waiver packet $5,000–$20,000. Portfolio retainer optional after 3 projects.
Reject hourly: Misaligns with automation; buyers buy payment unlock, not hours.
Pricing legality: No contingency on federal funds released or penalties avoided (could look like kickback / conflict). Fixed fees only. We do not take a share of project payments. Inferred best practice; confirm with counsel.
| COGS element (per 200-SKU project) | Launch | Day 90 |
|---|---|---|
| Model inference + OCR | $40–$120 | $25–$80 |
| Hosting/storage/CRM | $30–$60 | $20–$40 |
| Operator chase labor | 8–14 hrs ($280–$700) | 4–8 hrs |
| Specialist review | 3–5 hrs ($450–$1,000) | 1.5–3 hrs |
| QA sample | 0.5–1 hr | 0.4–0.8 hr |
| Rework buffer | 8–12% of labor | 4–7% |
| Target gross margin | 45–55% | 55–70% |
| Revenue / FTE target | $350k–$550k at scale | |
Automation %: launch ~55% of steps · day 90 ~70% · year 1 ~80% (chase still partly human).
16 Nonlinear scaling plan
- Throughput: 1 specialist supervises 4–6 active projects/week by day 90 via exception-only review.
- Cycle time: median SKU cert close 5–12 business days (manufacturer-dependent).
- Rework <8%; quality failure (owner reject of our packaging) <3%; escalation to counsel <5% of projects.
- Margin expands as manufacturer graph caches reusable letters (still project-stamped) and agency checklists harden.
- CAC payback target <3 months on project fees; lead-magnet→consult 8–15%; consult→pilot 25–40%; pilot→paid 60–80% Inferred.
17 Moat & Sam Altman test
Model improvement strengthens OriginVault by cutting extraction/chase cost and improving letter QA. Defensibility = (1) manufacturer response graph + known good signatories, (2) agency-specific package formats owners recognize, (3) specialist trust at payment chokepoint, (4) audit trails that survive Single Audit / OIG sampling.
18 Buyer-specific go-to-market
Primary motion: founder-led outbound to project controls + channel via municipal engineers, SRF program consultants, and construction CPAs — not creator waitlist-first. Content/AEO supports inbound but does not replace outbound.
| First 50 prospects | GCs with active FHWA/SRF/CDBG bids in 3 target states; specialty mechanical/electrical subs on those jobs. |
| Triggers | NTP; pay-app reject; obligation after Oct 2025/2026; owner BABA kickoff meeting. |
| Outreach wedge | “We’ll return a payment-ready BABA cert vault for Project X in 15 business days — fixed fee.” |
| Credibility asset | Anonymized redacted package + agency checklist crosswalk. |
| Sales cycle | 2–6 weeks for single project; longer for portfolio. |
Distribution proof table
| Channel | Why ICP reachable | First angle | Conv. assumption | Proof | Measure | Follow-up |
|---|---|---|---|---|---|---|
| LinkedIn outbound | Project controls titles public | Pay-app withhold teardown | 3–6% reply | Trade articles on BABA burden | Reply→meeting | Diagnostic offer |
| SRF/municipal engineer referrals | They see incomplete files | Reduce their review cycles | 1 in 5 warm intros | Spec payment-hold language | Intro→pilot | Co-branded checklist |
| AGC / AWWA chapters | Contractor density | Oct 2026 55% workshop | 10–20 leads/event | FHWA rule | Event→waitlist | Office hours |
| Search / AEO | “BABA certification letter requirements” | Field checklist lead magnet | 2–5% to consult | Query demand inferred | Magnet→booked call | Sequence |
| Construction CPA / advisory partners | Already in trust loop | White-label package | Partner-dependent | Cherry Bekaert category | Referral count | Rev share |
First 30 days of content
- 10 posts: generic vs project-specific letters; iron/steel vs manufactured; Oct 2026 55% cliff; pay-app withhold examples; de minimis myths; kit classification; permanently-incorporated gray zones; waiver timeline reality; FCA risk without legal advice; supplier chase scripts.
- 3 teardowns: redacted bad letter; incomplete pay-app exhibit; misclassified HVAC unit.
- 2 magnets: “BABA Letter Field Checklist” + “Obligation-Date Rule Card (FHWA).”
- 1 live review: office hours on 10 anonymous SKUs.
- 1 outbound diagnosis template: 12-line project gap memo.
Lead magnet & waitlist
Free BABA Payment-Risk Diagnostic: upload bid schedule sample → AI draft category map + missing-cert estimate → specialist 20-min review. Waitlist CTA for pilot cohort (cap 8). Qualifies when ≥30 covered SKUs and active federal funding.
19 Pilot design and early-demand trap
- Pilot cap: 8 projects / 5 customers max.
- Success: ≥90% SKU completeness without heroics; median chase ≤10 business days; owner accepts package; COGS tracked per SKU.
- Refuse: custom on-site inspections, unrelated Davis-Bacon payroll, full ERP builds.
- After 5: harden intake + letter field QA. After 10: harden SOPs/templates. After 20: pause until COGS/rework measured.
20 Competitive landscape
| Player | Type | Gap vs OriginVault |
|---|---|---|
| Cherry Bekaert / big-4 advisory | Services | Expensive, slow for mid-market single projects |
| Free Market America | Sourcing/docs support | Closer; differentiate on AI production system + payment-package SLA |
| US Made Supply / manufacturer marketplaces | Product discovery | Helps find products; does not run DFY chase/file for contractor |
| Internal project controls | Do-it-yourself | Labor shortage; inconsistent letter quality |
| Construction SaaS modules | Software | Customer-operated; no manufacturer chase engine |
Anti-duplication
Not IRA-PWA (labor/payroll). Not certified payroll. Not generic “AI for construction.” Narrow wedge = domestic-content evidence production for payment and audit under BABA/agency overlays.
21 Regulation, compliance, and licensing boundary
- AI may: extract, classify hypotheses, draft chase, parse letters, assemble packages, draft waiver narratives.
- Operators may: contact manufacturers, track exceptions, format exhibits.
- Specialists must: approve categories/letter sufficiency; decide waiver-prep vs escalate.
- Licensed counsel (client’s or ours, fractional): FCA exposure opinions, disputed legal interpretations — not routine packages.
- Client must: sign contractual pay-app certifications and remain legally responsible for truthfulness.
- We must not claim: we “certify” products as BABA-compliant to the government; we prepare evidence and specialist QA.
- Privacy: project docs may include pricing — SOC2-minded controls; no unnecessary PII.
22 Compact founding team and expert map
| Role | Why | FT/Fractional | Timing |
|---|---|---|---|
| Domain specialist (ex-GC compliance / SRF) | Chokepoint trust | FT or heavy fractional | Day 0 |
| Ops lead | SOPs, chase SLAs | FT | Day 0 |
| Automation/AI engineer | Engine | FT or fractional | Day 0 |
| Construction counsel | Boundary opinions | Fractional | As needed |
| Sales/channel | Outbound + partners | Fractional→FT | After 3 pilots |
| QA owner | Red-team | Shared with ops | Day 0 |
What the human expert actually does
| Task | License | Min launch | Min d90 | Automation path | Quality risk | Cannot automate | Audit trail |
|---|---|---|---|---|---|---|---|
| Category edge-case approval | None (competency) | 25 | 12 | Rules+model suggest | Misclass → pay reject | Ambiguous kits/fixtures | Decision log |
| Letter sufficiency sign-off | None | 20 | 10 | Field extraction QA | Generic letter accepted | Novel manufacturer formats | Versioned PDF hash |
| Waiver strategy | None / counsel if legal | 40 | 25 | Draft narrative | Wrong waiver type | Owner politics | Packet versions |
| Client briefing | None | 30 | 20 | Auto summary | Overpromise | Trust | Call notes |
23 Exhaustive risk register
Agency template fragmentation
Mitigation: Maintain per-agency playbooks; start FHWA+SRF only
Leading indicator: Checklist drift tickets
Manufacturer non-response
Mitigation: Multi-channel chase + client escalation clause
Leading indicator: % SKUs >14d open
FCA association / client false cert
Mitigation: Refuse known-false; engagement letter; counsel escalation
Leading indicator: Escalation count
Misclassification of products
Mitigation: Specialist dual-review on low confidence
Leading indicator: Owner rejects
Construction SaaS launches module
Mitigation: Double down on DFY chase SLA
Leading indicator: Competitor launches
Political softening of BABA
Mitigation: Diversify agencies; monitor MIAO
Leading indicator: Waiver policy changes
Scope creep into Davis-Bacon/PWA
Mitigation: Hard SOW exclusions
Leading indicator: Custom hours
Pricing below COGS on hard projects
Mitigation: SKU-band pricing; kill switch
Leading indicator: GM per project
Data security of bid pricing
Mitigation: Encryption, access logs, DPA
Leading indicator: Incidents
Talent: scarce specialists
Mitigation: Train operators; gold examples
Leading indicator: Hire funnel
Waiver timelines blow SLAs
Mitigation: Set expectations; separate waiver SKU
Leading indicator: Waiver cycle days
Over-reliance on inferred TAM
Mitigation: Pilot revenue before scale spend
Leading indicator: Paid pilots
24 Tech stack & build plan
- Week 1–2: Airtable/Notion vault + Gmail/Outlook chase sequences + Claude/GPT extraction scripts + checklist PDF templates.
- Week 3–6: Ingest pipeline, manufacturer CRM, letter parser, completeness scorer, client view-only portal.
- Week 7–12: Agency playbook pack (FHWA, EPA SRF), waiver drafter, analytics on chase conversion.
- Avoid building a full construction ERP; integrate via CSV/API later.
25 Metrics & KPIs
Throughput projects/FTE · cycle time per SKU · rework % · gross margin · COGS/project · revenue/FTE · escalation % · automation % · evidence completeness % · quality failure % · customer acceptance % · pilot conversion % · manufacturer response rate · pay-app doc pass rate.
26 What could kill this
- Federal rollback that restores broad manufactured-product waivers and collapses urgency.
- Incumbent platform bundles “good enough” DFY via partner network at scale.
- Inability to get manufacturers to respond — if chase conversion <40%, model fails.
- One FCA scandal involving a client who ignored our refuse-to-falsify policy (reputational contagion).
27 90-day validation and launch plan
| Window | Actions | Kill/continue criteria |
|---|---|---|
| Days 1–7 | SOW + engagement letter; FHWA/SRF checklists; 20 prospect list; diagnostic landing page | Cannot name 20 real projects → pause |
| Days 8–30 | 3 design partners; manual fulfillment; instrument COGS; publish 10 posts | <1 paid pilot LOI → revisit ICP |
| Days 31–60 | Complete 3 packages; measure chase conversion; harden letter QA | Chase <40% or GM <35% → redesign |
| Days 61–90 | Cap at 8 pilots; pricing test; partner conversations; decide scale | Owner acceptance <80% → no-go scale |
7 / 30 / 90 day snapshots
7-day: offer page, checklist magnet, 50 outbound, counsel-reviewed engagement letter.
30-day: first paid package in flight, weekly feedback loop, COGS dashboard.
90-day: 5–8 completed packages, playbooks for 2 agencies, go/no-go on hiring second specialist.
28 Sources
- OMB M-24-02 Buy America Implementation Guidance
- Federal Register — OMB 2 CFR Part 184 final guidance (Aug 23, 2023)
- FHWA Manufactured Products Final Rule Q&A (updated Jan 5, 2026)
- FHWA Buy America Requirements for Manufactured Products final rule (90 FR 2932)
- FHWA newsroom — manufactured products waiver updates
- Cherry Bekaert — BABA compliance rules & services
- Free Market America — BAA/BABA documentation support
- US Made Supply — Buy America compliance guide for contractors
- Wisconsin DEHCR — BABA compliance documents / payment holds
- HUD PIH 2025-06 — BABA implementation notice
- Hinckley Allen — BABA exposure / FCA tips for contractors
- DOJ — FCA settlements & judgments exceed $6.8B FY2025
- Construction Business Owner — what contractors should know about BABA
- DOE — Build America, Buy America program page
- Law.com — growing fraud risk of domestic-origin claims
Generated 2026-07-09T18:02:00Z. Claims labeled Verified / Inferred / Unverified in-matrix. This blueprint is not legal advice.