DoD Moving Rules Put Small Firms at Risk

The Defense Department’s proposed moving rules could push many small companies out of the military market, Movers for America says, even as service members rely on those companies to move their household goods. The department’s Personal Property Activity issued the rules earlier in October and accepted public comments through Oct. 26. The rules now sit between the people who need moves and the workers who provide them.

“Our industry is primarily made up of small businesses, and the cost of getting to level 2 CMMC compliance is very high,” executive director Katie McMichael told Federal News Network. She said many companies rely on independent contractors who work for themselves and serve different parts of the country, making it difficult to bring all drivers and crews into compliance. “A lot of folks are leaving to go work in the general freight trucking space,” she said.

Who Pays for Compliance

The proposed rules require Level 2 Cybersecurity Maturity Model Certification compliance. Movers for America questioned whether that requirement fits the personal information movers handle: service members’ full names, addresses and phone numbers, used to coordinate a move. McMichael said food-delivery drivers collect more information because they also keep customers’ credit card information on file. “We just fundamentally think that the application of CMMC to our industry is not necessary,” she said.

A recent Movers for America survey found that nearly half of moving professionals said they might scale back their Defense Department business if Level 2 compliance becomes mandatory. McMichael warned that a smaller pool of companies could leave the moving capacity service members need in short supply. “When you look at the capacity that's needed for industry to get these service members moved from point A to point B, we can't afford to have almost half of the industry scale back. You're not going to get your service members moved from where they need to be,” she said.

The proposal also bars service members from sponsoring or escorting movers onto military installations. McMichael said service members shouldn't have to sponsor movers, but they should keep the option. “Base access is a hard thing as it is, and we don't need to make it more difficult by implementing rules that prohibit the ability to make it easy. The language is very strong in prohibiting it, and that just exacerbates the problem,” she said.

Access, Delays and Penalties

McMichael also challenged the assumption that a mover who can't get onto a base must have committed a serious offense. “And this narrative that not getting on base means you must have truly done something horrific in your past — that is not the case. That's not the norm. I don't think that's an accurate representation of the drivers and the crews that are working hard to get service members' things delivered,” she said.

Movers for America said companies shouldn't face penalties when they can't gain access to a base. Base commanders set the access standards, McMichael said, while the Personal Property Activity doesn't control those decisions. “Because it changes so much, I think penalizing the industry for base access for something that's out of everyone's control seems a little punitive,” she said.

The coalition also wants the performance-evaluation period extended from nine months to one year. It called for changes to the $75 waiting-time fee, which it said doesn't adequately compensate crews delayed while trying to enter military bases. Those practical costs fall on the people doing the work when access rules and compliance demands shape the job.

Feedback Meets the Apparatus

So far, the response has involved industry lobbying and meetings, not direct action or mutual aid. McMichael said the Personal Property Activity has held multiple in-person meetings with industry and collected feedback. Defense Department leadership had recently announced plans to transition the activity toward a standalone agency.

Officials expected the final rules by the end of November. McMichael said people in the industry felt positive about the direction of the relationship with the activity, but were waiting to see whether officials would accept their requested changes. “This is our first real iteration of going through the business rules together,” she said. “So I think what everyone is anxiously awaiting is whether they are going to listen to our feedback and work with us and make these changes that we're looking for.”