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White House Announces “Revolutionary FAR Overhaul”: What to Know

Through a duo of Executive Orders (EOs), issued on April 15 and 16 respectively, President Trump announced “a first-of-its-kind overhaul of Federal procurement policy.” The rewrite represents a once-in-a-generation...more

DOJ Settlement Highlights Customs, FCA Risks for Importers

On March 25, 2025, the U.S. Department of Justice (DOJ) announced an $8.1 million settlement in a civil case under the False Claims Act (FCA) related to alleged customs evasion by a California importer of wood flooring. The...more

[Event] Inaugural D.C. Compliance & Government Investigations Seminar - April 8th, Washington, DC

We are pleased to invite you to the inaugural D.C. Compliance & Government Investigations Seminar, hosted by Bass, Berry & Sims in collaboration with Watermark Strategies. This complimentary seminar will build upon the...more

SBA’s OHA Finds Initial Offer To Be Of Consequence, Not Final Proposal Revision, for the “180-Day Rule”

On February 19, the Office of Hearings and Appeals (OHA) denied an appeal from an unsuccessful bidder who argued the awardee was large due to an acquisition that occurred while the award was pending. OHA found that Small...more

Part II: SBA Final Rule Updates Negative Control Requirements and 8(a) Ownership Rule

On December 17, the Small Business Administration (SBA) published its final rule detailing new recertification requirements following mergers and acquisitions (M&A), new language around negative control for affiliation...more

New SBA Rule Overhauls Small Business M&A Landscape

On December 17, the Small Business Administration (SBA) published its final rule in response to its August 2024 proposed rule and the ensuing comments from the industry. The rule will have a substantial impact on the...more

President Trump Revokes Executive Order 11246

“Ending Illegal Discrimination and Restoring Merit-Based Opportunity” (Order) is one of President Trump’s most recent executive orders. The Order was signed on January 21, 2025. The Order revoked Executive Order EO11246...more

Bid Protest Minute: Bidders Beware – Clearly Stated Solicitation Requirements Control

On November 15, the Government Accountability Office (GAO) denied a protest from AtVentures, LLC, a mentor-protégé joint venture, who challenged its exclusion from consideration for award on the basis that it was able to use...more

“Small” Space Companies: Growth Comes at a Cost

Space has become central to protecting U.S. national security interests as Americans increasingly rely on space-based services to support everyday life. As a result, the U.S. government has bolstered investment in the space...more

DoD Announces Cybersecurity Maturity Model Certification 2.0 Final Rule (Finally!)

After numerous fits and starts, on October 14, the Department of Defense (DoD) published a final rule implementing the Cybersecurity Maturity Model Certification (CMMC) program. Borne from documented deficiencies in the...more

DOD’s Office of Strategic Capital Announces First Notice of Funding Availability

On September 30, the Department of Defense’s (DOD) Office of Strategic Capital (OSC) announced a notice of funding availability (NOFA) of up to $984 million in loans aiming to support the financing of certain covered...more

SBA Seeks to Make Changes to Recertification Requirements for Multiple-Award Contracts

On August 23, the U.S. Small Business Administration (SBA) issued a proposed rule that would make significant changes to SBA’s recertification requirements. Most notably, the rule would change when size and socioeconomic...more

Bid Protest Minute: COFC Makes It Clear; SAM Registration Can Sink a Proposal

On September 10, the Court of Federal Claims (COFC) issued an opinion in Zolon PCS II, LLC v. United States, holding that the National Geospatial-Intelligence Agency (NGA or Agency) unreasonably issued a deviation from FAR...more

SBICCT Initiative Adds New Tool to Drive Innovation

The Department of Defense (DoD) has long searched for ways to foster innovation in the defense industrial base by harnessing US comparative advantages like our capital markets and American technological innovation...more

HHS Proposed Rule Seeks to Align Health IT Procurement Standards to Leverage Interoperable Data

On August 9, the Department of Health and Human Services (HHS) published a proposed rule that seeks to amend and update the Health and Human Services Acquisition Regulation (HHSAR) to align health IT procurement requirements....more

DoD Publishes Proposed Rule to Amend DFARS Provisions Related to the CMMC 2.0 Program

On August 15, the Department of Defense (DoD) published a proposed rule to amend the Defense Federal Acquisition Regulation Supplement (DFARS) to incorporate contractual requirements related to the proposed Cybersecurity...more

OHA Decision Reaffirms SBA’s Strict Adherence to Joint Venture Requirements

In a recent decision, the Office of Hearings and Appeals (OHA) affirmed a Small Business Administration (SBA) Area Office’s size determination and held that procedural deficiencies in a contractor’s Joint Venture Agreement...more

SBA Final Rule Eliminates Self-Certification for Service-Disabled Veteran-Owned Small Businesses

On June 6, the Small Business Administration (SBA) issued a final rule that, effective August 5, 2024, implements a provision of the National Defense Authorization Act for Fiscal Year 2024 (2024 NDAA), which eliminates the...more

FAR Council Announces Proposal to Ban Government Purchases and Use of Certain Semiconductors

On May 3, the Department of Defense (DOD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA) issued an Advanced Notice of Proposed Rulemaking (ANPRM) that would prohibit executive...more

Department of Defense Issues Class Deviation Delaying Application of NIST SP 800-171, Revision 3

On May 2, the Department of Defense (DOD) issued a class deviation to DFARS 252.204-7012 “to provide industry time for a more deliberate transition upon the forthcoming release of [National Institute of Standards and...more

Tenth Circuit Gives Biden Administration Major Win in Contractor Minimum Wage Case

On April 30, the U.S. Court of Appeals for the Tenth Circuit affirmed a lower court’s ruling denying a bid from two outdoor recreation companies asking for a preliminary injunction on a 2021 Department of Labor (DOL) rule...more

New Rule Requires Agencies to Procure Sustainable Products and Services

On April 22, the Department of Defense, General Services Administration, and National Aeronautical and Space Administration (NASA) promulgated a final rule amending the Federal Acquisition Regulation (FAR) to implement an...more

Bid Protest Minute:  GAO Clarifies Certain “De Facto” Joint Venture Eligibility Issues

On March 22, the Government Accountability Office (GAO) sustained a protest challenging an agency decision finding the protester ineligible for award under both the Omnibus Diplomatic Security and Antiterrorism Act of 1986...more

Final Rule Expands Defense Industrial Base Cybersecurity Program Eligibility Criteria

On March 12, the Department of Defense (DOD) promulgated a final rule that expands the eligibility criteria for the Defense Industrial Base (DIB) Cybersecurity Program, a voluntary initiative aimed at bolstering the DIB’s...more

Dispensing of a Significant Jurisdictional Hurdle, Federal Circuit Holds Incorporated EULA Confers Jurisdiction

On March 6, the Federal Circuit held that a software company sufficiently established jurisdiction under the Contract Dispute Act (CDA) where its end-user license agreement (EULA) was incorporated into another contractor’s...more

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