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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

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

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

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

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

Proposed Rule Seeks to Bring Gender Pay Equity to Federal Contracting Community

On January 29, the Biden administration announced several policy initiatives aimed at addressing pay transparency and equity, including a proposed rule issued by the Department of Defense (DOD), General Services...more

Department of Defense Publishes Long-Awaited CMMC Proposed Rule

On December 26, the Department of Defense (DoD) published its long-awaited Cybersecurity Maturity Model Certification (CMMC) Program proposed rule, which places comprehensive cybersecurity and information security...more

New Rule Seeks to Streamline DoD Commercial Product and Service Procurements

On November 17, the Department of Defense (DoD) issued a final rule, implementing Section 874 of the National Defense Authorization Act (NDAA), clarifying that certain DoD-unique statutes and Defense Federal Acquisition...more

GAO’s 2023 Bid Protest Report: More Than Meets the Eye

On October 26, the Government Accountability Office (GAO) sent its annual bid protest report to Congress, which reflected a dramatic increase in protests filed following four straight years of decline. The report provides...more

GAO Assesses Health of the Defense Industrial Base

The health of the Defense Industrial Base (DIB) has been brought to the fore as the United States responds to wars in Ukraine and Israel. Unfortunately, according to the National Defense Industrial Association’s “Vital Signs”...more

UPDATE: 8(a) Reopens its Certify Site Welcoming New Applicants

On September 29, the Small Business Administration (SBA) reopened its Certify portal to new applicants seeking admittance into the SBA 8(a) program....more

SBA Issues Interim Guidance on 8(a) Program Following Ultima Ruling

On July 19, the U.S. District Court for the Eastern District of Tennessee ruled in favor of Ultima Services Corporation, prompting the pause of new 8(a) applications and necessitating a reorganization of the program’s...more

SBA Tidies Up 8(a) Rules in Welcomed Final Rule

Effective May 30, 2023, a Small Business Administration (SBA) final rule made some notable changes to SBA’s 8(a) Business Development (BD) program, a valuable resource for those firms owned by socially and economically...more

Department of Defense to Require Contractors Proactively Provide DCMA with Export Authorizations

On March 22, the Department of Defense (DOD) issued a proposed rule that would amend the Defense Federal Acquisition Regulations (DFARS) to require certain contractors to provide the Defense Contract Management Agency (DCMA)...more

SBA Proposed Rule Permits Prime Contractors to Receive Subcontracting Credit from Any Tier

On December 19, 2022, the U.S. Small Business Administration (SBA) issued a proposed rule that would amend the SBA regulations to implement Section 870 of the National Defense Authorization Act (NDAA) of 2020. Section 870...more

Joint Venture Past Performance Can Be Gleaned from Previous Prime-Sub Relationships

Over the last few years, the government has shifted away from lowest price technically acceptable valuations placing a larger importance on past performance. The past performance requirement can sometimes create obstacles for...more

Task Orders May Carry Implicit Size Recertification Requirements

Generally, when a business is awarded a multi-year IDIQ contract, it retains its “small” business designation unless a contracting officer (CO) requires the business to recertify its size status, and has since grown larger...more

Attention SBIR Applicants…Remember that Affiliation Rules Still Apply

The Small Business Innovation Research (SBIR) program has an interesting construction. With seemingly no competition to bring size protests and the successful completion of a previous grant before a second grant, the unusual...more

New Legislation Strengthens Disclosure Requirements for Potential Organizational Conflicts of Interest

On December 27, President Biden signed the Preventing Organizational Conflicts of Interest in Federal Acquisition Act into law. The legislation, ushered through Congress by a bipartisan group of backers, strengthens existing...more

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