# Key Personnel Substitution After Award: The 128-Day Problem

> Your proposal named key personnel, and the contract holds you to them. What substitution requires when one leaves, and the part of 128 days you control.

_By Oswald B. · Published 2026-09-28_

Key personnel substitution is what happens when someone your proposal named leaves after award. Public A/E contracts commonly require the client's written approval before you replace a named person, and the replacement has to be at least as qualified. The approval runs on your paperwork. The hiring doesn't: Zweig Group puts the most critical roles at 128 days to fill.

Most firms plan hard for the proposal and not at all for this moment. It is worth planning for, because the proposal made a promise and the contract holds you to it.

## What Zweig's 128 Days Measures

Zweig Group's [2026 Workforce Policies + Practices Report](https://zweiggroup.com/blogs/the-zweig-letter/2026-aec-workforce-benchmarks-recruiting-retention), released August 19, 2026, has this line: "The average time to fill a position is 54 days, increasing to 128 days for the most critical positions."

One caution before using it. "Most critical positions" is Zweig's phrase, about hiring. "Key personnel" is a contract term, about the people a client selected you for. They are not the same list. But the roles a proposal names, the project manager and the discipline leads, are the ones a firm is least likely to fill quickly. If one leaves, 128 days is a fair guess at how long an outside hire takes. That is more than four months of a contract running without the person the client chose.

This is the post-award side of a problem I wrote about earlier. [The talent shortage changed what resumes are for](/blog/engineering-talent-shortage-key-personnel) before award: they became the proof of depth. This piece is about what happens after the client accepts that proof and one of the names walks out.

## What the Contract Says When a Named Person Leaves

The wording varies by client, but the shape is consistent. Two examples, one federal and one state and local:

| Source                                                                                                                                                                                               | What it requires                                                                                                                                                                                         |
| ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| [HSAR 3052.215-70](https://www.acquisition.gov/hsar/3052.215-70-key-personnel-or-facilities.), Key Personnel or Facilities (DHS)                                                                     | Notify the Contracting Officer in writing, submit "sufficient information to support the proposed action," and do not remove or replace the person "until the Contracting Officer approves the change"   |
| [Caltrans Contract Manager Reference Guide](https://dot.ca.gov/-/media/dot-media/programs/local-assistance/documents/guide/cmrg-chapter-1-contract-management.pdf), A&E contracts for local agencies | No substitution without "prior written approval," and the replacement "must be as qualified as the original, and at the same or lower cost." Without approval, costs may be ineligible for reimbursement |

Read those together and the obligation is clear. You cannot just swap in whoever is free. You have to show the client, in writing, that the new person matches the one they selected.

Under [qualifications-based selection](/blog/qualifications-based-selection), that makes sense. The client chose your firm largely because of the people it named. Replacing one quietly would undo the selection.

## Why 98% Retention Makes This Worse

The same Zweig release has a figure that sounds reassuring: "Retention of key talent, including top performers, leaders, and licensed professionals, reaches a median of 98%."

That is a very good number, and it is exactly why most firms have no substitution plan. When key people almost never leave, planning for it feels like a waste of an afternoon. So when it does happen, the firm builds the substitution package from scratch, under pressure, while the client waits.

Low odds don't mean low stakes. A firm with dozens of named people across several multi-year contracts will face this eventually. The 98% only tells you it will be a surprise.

## You Can't Shorten 128 Days. You Can Shorten Your Part.

Hiring takes as long as it takes. What a firm controls is how fast it can answer the client's real question: who else here is as qualified as the person we lost?

1. **Name a likely successor for every key role when you submit.** Not in the proposal, in your own records. If the lead leaves in month six, the first candidate should already be known.
2. **Keep the successor's qualifications as current as the lead's.** Registrations, certifications, relevant projects. The client will compare them line by line, so an out-of-date record loses time and credibility.
3. **Draft the substitution request before you need it.** Most requests carry the same elements: the new person's resume, a side-by-side against the original, and a note on how the work continues. Know what your major clients ask for.
4. **Check cost as well as qualifications.** Caltrans' guide asks for "the same or lower cost." A senior replacement at a higher rate can stall approval even when the credentials match.

All four depend on the same thing: a current record of what your bench has done, kept where someone other than the departing person can find it. That is the kind of record [a reusable qualifications library](/blog/reusable-qualifications-library) is for, and it is what RFPM's workspace keeps in one place so a successor's resume is a search, not a reconstruction. Someone at the firm still decides who steps in.

The firms that handle this well won't hire faster than anyone else. They'll know on day one who can step in, and the paperwork will be the easy part.

## Frequently Asked Questions

### What is a key personnel clause?

A key personnel clause is a contract provision that lists the people essential to the work, usually the project manager and named leads, and restricts replacing them. It typically requires written notice, a justification, and the client's approval before the change, often with a replacement at least as qualified as the original.

### Can a firm replace key personnel without client approval?

Usually not. Clauses like HSAR 3052.215-70 bar removing or replacing a named person until the Contracting Officer approves. Caltrans' guidance for local A&E contracts requires prior written approval and warns that unapproved substitutions can make costs ineligible for reimbursement.

### How long does it take to replace a key person?

Approval can move quickly if the substitution request is complete. Hiring is slower. Zweig Group's 2026 report puts the average time to fill a position at 54 days and the most critical positions at 128. An internal successor with a current record is usually the fastest path.

---

Canonical HTML: https://rfpm.ai/blog/key-personnel-substitution-after-award · Site overview: https://rfpm.ai/llms.txt · Sitemap: https://rfpm.ai/sitemap.xml