The Cost of Getting it Right: How One Colorado Project Turned BABA Risk into Budget Protection

Strategic teams are moving early. They’re asking better questions. They’re partnering with ABW Consulting and they’re getting it right.

Does it ever feel like compliance is getting more complicated and you’re not being given the tools to actually stay ahead of it? Like somehow you’re responsible for navigating a maze, but no one handed you the map?

Right around the end of the year, I was catching up with a colleague who was feeling exactly that. They had a big infrastructure project with federal funding, a fast approaching schedule, and a growing list of compliance obligations that seemed to fall in everyone’s lap and no one’s job description.

Here’s the thing: The real risk lies in waiting. Waiting to clarify roles. Waiting to see who’s responsible for what. Waiting to document decisions after the fact. It’s the number one reason critical paperwork gets missed and reimbursement is delayed or denied entirely.

When federal dollars are involved, there’s no such thing as “good enough.” Ambiguity is the costliest risk of all.

That’s when ABW Consulting joined the conversation. Not to point fingers or throw binders around, but to step in as a problem solving collaborator, someone who could untangle the red tape and make sure everyone knew what compliance actually looked like before it became a problem.

Buy America, Build America (BABA) compliance isn’t just about checking a box. It’s about protecting your reimbursement and your project.

If you’re not:

• Differentiating clearly between construction materials, manufactured products, and iron/steel components

• Monitoring cumulative foreign content against the 5% or $1 million de minimis threshold

• Verifying that your product was manufactured in the United States, regardless of component origin

• Ensuring that you have the correct documentation and supplier attestations to prove compliance

• Preparing now for documentation strategies and foreign sourcing cost exposure even before Certificates of Origin are required in 2026

  
  

…then you’re operating at risk.

And here’s what’s even more pressing: The 45% component threshold for manufactured materials is as much about compliance as it is about market vulnerability. If you're not tracking which components are foreign sourced, you can’t prepare for unexpected cost surges or justify them when cost increases trigger change orders.

That’s exactly where our client was stuck and that’s where ABW’s approach changed the game.

We didn’t just offer a checklist. We offered a system.

Using custom developed GPTs and AI agents, we:

• Automated material classification into the correct BABA categories

• Flagged gaps in supplier documentation in real time

• Built a dynamic tracker to monitor de minimis use and material sourcing trends

• Created early alerts for cost exposure based on foreign content

• Standardized document formats for easier audit reviews and contractor coordination

Let’s break this down by who benefits:

For Contractors:

• Reduce costly change orders by catching sourcing risks early

• Minimize rework from incomplete or incorrect documentation

• Build credibility with owners by proactively tracking and communicating risk

• Use AI assisted workflows to reduce admin time and protect against audit exposure

For Cities, Counties, and Municipalities:

• Ensure federal reimbursements aren’t delayed or denied due to preventable errors

• Gain a second set of eyes and a standardized process across internal teams

• Reduce uncertainty around responsibility and compliance tracking

• Clearly communicate expectations with designers, engineers, and contractors

Let’s talk real results:

When ABW Consulting was asked to support this $20 million municipal infrastructure project, we brought clarity and structure to a fast moving and federally funded effort. Our involvement started early during the material planning and review phase so we could help the team identify potential compliance risks before they became costly problems.

Why was that so important? Because for many state and local infrastructure projects, up to 80 percent of the funding can come from federal sources. In this case, that meant $16 million of the $20 million budget is tied directly to federal reimbursement eligibility. That’s $16 million at risk if the project failed to meet BABA compliance, whether from a missing document, a misclassified material, or an unverified manufacturing claim. Every overlooked component, every undocumented sourcing decision, and every misunderstood compliance category could cost thousands, or even millions, if the reimbursement is delayed or denied.

Our AI agents and custom GPTs didn't just check boxes they showed the team where their blind spots were and how to address them.

We:

• Walked through over 250 submittals and helped classify materials by BABA category

• Identified documentation gaps and outlined what needed to be requested from vendors

• Flagged items that would need cost justification if prices changed due to international sourcing risk

• Built a custom tracking dashboard for use throughout the project lifecycle

Because of our early involvement:

• The team was able to swap out several non compliant products before they were ordered

• They identified numerous documentation delays that would’ve impacted payment and reimbursement cycles

• And they established a workflow that will keep the project audit ready every step of the way

These aren't' just process improvements, they are project protections. Each correction helped prevent delays, change orders, and reimbursement holds that could’ve stacked into six figure risks.

And they were made possible because we acted early.

That’s the ABW difference.

We rolled up our sleeves and worked alongside them because while they own the project, we brought the clarity and structure that made real compliance possible. Before ABW Consulting stepped in, they didn’t even know what questions to ask. We developed the tools, trained them to use them, and helped them build a workflow that matched the scope and funding risk of the project.

We aren't just consultants we are collaborators, advisors, and the steady hand when the rules feel murky. By the time decisions need to be made, they aren't scrambling. They are prepared.

The project is still early in execution, but the foundation is solid. The city, contractors, and engineers are now aligned on what to track, how to track it, and what documentation will be needed when reimbursement begins. We’ve already helped the team gain the clarity and tools they need to get ahead of the compliance curve. They know what to track, what documentation to ask for, and how to flag risks before they cause delays.

We’ll continue to support them as the project evolves and share what we learn.

But what’s already clear is this:

• They’ve closed critical compliance gaps before procurement ramped up

• They’re positioned to catch sourcing and documentation issues early

• And they’re building the confidence to manage this process proactively, with the right partner by their side

But imagine for a minute the scale of that impact on a $100 million capital investment.

Or a 30 year water infrastructure program.

Or a regional transportation system.

The value ABW Consulting delivers grows with the complexity of your project.

Our custom GPT's and AI Agents are designed to flex, adapt, and scale with your scope, helping you track risk, document sourcing, and stay compliant from day one.

If you’re a city, county, contractor, or construction manager navigating federally funded infrastructure, the time to think about BABA isn’t when your submittal gets kicked back. It’s now.

Let’s talk before small oversights become big problems. Visit abwconsulting.ai or message me directly.

We’re ready when you are.