A. At this time the Federal Government (GSA, FTA, etc.) does not treat CM At-Risk procurements as A-E (Brooks Act) procurements. The current policy is to treat this kind of contract as one for construction (or, if you prefer, as Design-Build where the preponderance of the work is construction, not A-E services). Thus the Federal approach is to use a negotiated competitive RFP (pursuant to FAR Part 15) with price proposals from the CM At-Risk offerors. This being true, there doesn't appear to be a problem with the overhead cap, as there would be if this were an A-E procurement.