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GAO Bid Protest Annual Report to Congress for FY 2024

On November 18, the Government Accountability Office ("GAO") released its much-anticipated Bid Protest Annual Report to Congress for Fiscal Year 2024, which was submitted to Congress on November 14. GAO's annual report is...more

FAR Council Issues Interim Rule Removing SAM.gov Registration Continuity Requirement

On November 12, the Department of Defense, General Services Administration, and the National Aeronautics and Space Administration (together, the "FAR Council") issued an interim rule, effective November 12, 2024, to amend the...more

SBA Issues Proposed Rule to Require "Rule of Two" for Orders Under Multiple Award Contracts

Today, the Small Business Administration issued a proposed rule that would expand the application of the "rule of two" (for small business) to orders under multiple award contracts. The proposed rule is welcome news for small...more

DOD Finalizes CMMC 2.0 Program Final Rule

On Tuesday, October 15, 2024, the U.S. Department of Defense (“DOD”) issued its final rule for its much anticipated Cybersecurity Maturity Model Certification (“CMMC”) program. The CMMC program will eventually require one of...more

7 (Other) Reasons to Intervene in Bid Protests: What Awardees Need to Know

With just a week to go in FY24, federal agencies are rushing to spend those "use it or lose it" dollars. And while there are a number of reasons that support filing a bid protest when you're an unsuccessful offeror – this...more

SBA Proposes Rule That Will Change M&A Landscape for Small Business, Recertifications to Impact Award Eligibility

The Small Business Administration ("SBA") recently issued a proposed rule that changes the effect of a concern's size recertification following mergers and acquisitions ("M&A") activity. Notably, the proposed rule is...more

SBA Proposes to Amend its Negative Control Rule, Which Could Have Major Implications for Small Businesses and Minority Shareholder

Recently, the Small Business Administration ("SBA") issued a proposed rule, which could significantly alter the status quo for permissible negative control. Impacted small businesses and their minority shareholders and...more

GAO Decision Highlights Agency’s Evaluation of Mentor-Protégé Joint Venture, But Could Unintentionally Lead Industry Astray on...

A recent Government Accountability Office (“GAO”) decision highlights the Small Business Administration’s (“SBA”) regulations relating to agency evaluations of a mentor-protégé joint venture’s past performance and experience,...more

White House Issues New National Security Memorandum on Critical Infrastructure

On April 30, 2024, the White House announced that President Biden signed a new critical infrastructure memorandum, titled National Security Memorandum on Critical Infrastructure Security and Resilience ("NSM-22"). This new...more

Cyber Agency Issues Proposed Rule on Cyber Incident Reporting for Critical Infrastructure

In early April, the Cybersecurity & Infrastructure Security Agency (CISA), within the US Department of Homeland Security, released a Notice of Proposed Rulemaking (NPRM) regarding the implementation of the Cyber Incident...more

GAO Decision Shows that Even a 1-Day Lapse in SAM Registration Can Sink Your Bid

As many government contractors know all too well, doing business with the government requires contractors to become familiar with and adhere to countless rules and regulations governing the procurement process. As shown in a...more

FAR Council Publishes its Semiannual Regulatory Agenda

On February 9, 2024, the Federal Acquisition Regulatory Council ("FAR Council") – Department of Defense, General Services Administration, and National Aeronautics and Space Administration – published its Semiannual Regulatory...more

White House Announces OMB Guidance to Increase Small Business Contracting Opportunities

Last week, the White House announced that the Office of Management and Budget ("OMB") issued guidance to help small businesses in the federal contracting marketplace. With the guidance, as the announcement states, the...more

Recent GAO Decision Highlights GAO's Jurisdiction Over Protests Involving Task Orders

The recent bid protest decision in ELS, Inc., B-421989, December 21, 2023, 2023 CPD highlights an important aspect of bid protest litigation before the U.S. Government Accountability Office ("GAO"): task order jurisdiction....more

SDVOSB Self-Certification Grace Period to Expire: Submit Applications by Dec 31 To Remain Eligible While Applications are Pending

The 2023 clock is winding down, meaning some folks are planning New Year's Eve parties, and others are googling the lyrics to Auld Lang Syne. For service-disabled veteran-owned small businesses ("SDVOSB"), the end of the...more

Recent FCA Settlement Highlights Small Business Certification Issues in Private Equity Transactions

The Department of Justice ("DOJ") recently announced a $1.75 million false claims settlement with a contractor that "improperly obtained government contracts that were set-aside for small businesses." The DOJ settlement...more

GAO Bid Protest Annual Report to Congress for FY 2023

Last week, the U.S. Government Accountability Office ("GAO") published its much anticipated Bid Protest Annual Report to Congress for Fiscal Year 2023. GAO's annual report is required under the Competition in Contracting Act...more

SBA to Require All Individually-Owned 8(a)s to Affirmatively Establish Social Disadvantage

We recently wrote about a federal court decision in Ultima Servs. Corp. v. U.S. Dep't of Agric., which held that the "rebuttable presumption" of social disadvantage under Small Business Administration's ("SBA") 8(a) Program...more

Court Enjoins Rebuttable Presumption in 8(a) Program: What's Next for Future, Current Participants?

On July 19, 2023, the U.S. District Court for the Eastern District of Tennessee held in Ultima Servs. Corp. v. U.S. Dep't of Agric. that the "rebuttable presumption" of social disadvantage under Small Business...more

Hello Q4: SBA Clarifies 8(a) Sole Source Rules, Individual 8(a)s Have More Options for Larger Awards

The government's fiscal year ("FY") is coming to an end on September 30, which means the need for agencies to spend "use it or lose it" contracting dollars will steadily increase over the next couple of months. And, while the...more

DoD Issues Proposed Rule to Address Domestic Preferences for Defense Contracts

On June 9, 2023, the Department of Defense (“DoD”) issued a proposed rule to address domestic preferences – the Buy American Act – in DoD procurements. The proposed rule follows updates to the Federal Acquisition Regulation...more

FAR Council Publishes Rule to Ban TikTok Applications in Government Contracting

Last Friday, the Federal Acquisition Regulatory Council published an interim final rule ("IFR") to ban the use of a ByteDance Covered Application (i.e., TikTok) in government contracting. The IFR is effective June 2, 2023....more

Joint Venturers Beware – Underestimating the Importance SAM Registrations Can Sink Your Proposal

Protests filed at the U.S. Court of Federal Claims (“COFC”) differ in many ways from protests before the U.S. Government Accountability Office (“GAO”). For example, protests before GAO are uniform given that they are...more

7 Reasons to Intervene in Bid Protests

Every federal contractor knows how difficult it is to win a government contract. Indeed, contractors often start pursuing larger contracts or vehicles well over a year before the solicitation is even published. And, while...more

FY23 NDAA Includes Inflation Relief for Defense Contractors

Recently, the U.S. House of Representatives and Senate overwhelmingly approved the National Defense Authorization Act for Fiscal Year 2023 (“FY23 NDAA”). The legislation is welcome news for both the Department of Defense...more

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