As the second Trump Administration enters its third month, Covington’s Government Contracts Practice is continuing to track the latest developments related to recent executive actions.  This April edition of our key developments timeline has been condensed to provide a targeted overview of the developments this month most relevant to contractors.  For a detailed version of the timeline as of April 2, 2025, including background on some of the developments discussed below, please see our post here.

This timeline highlights key developments pertaining to recent executive orders (“EOs”) and other executive actions issued by the second Trump administration.  It focuses on issues most relevant to federal contractors and grant recipients, and is divided into five topics: (1) Federal Funding; (2) DEI and Gender; (3) Energy and Environment; (4) Trade and Foreign Aid; and (5) DOGE.  Covington’s Government Contracts Practice is continuing to track these and other developments and will plan to periodically update this timeline.

This timeline provides a high-level summary of recent events and is not exhaustive. In addition, this timeline was last updated on April 17, 2025.  To the extent you may have questions regarding any of the developments discussed below — or other matters — please reach out to a member of Covington’s Government Contracts Practice.

1. Federal Funding

2. DEI and Gender

  • April 1: In Chicago Women in Trades v. Trump, N.D. Ill. issued an amended TRO blocking certain provisions of EO 14173.  Among other things, the TRO prohibits the Department of Labor from requiring “any grantee or contractor to make any ‘certification’ or other representation pursuant to the Certification Provision [of EO 14173].”  The “Government” is also prohibited from initiating False Claims Act enforcement against the plaintiff pursuant to the certification provision.
  • April 4: In State of California v. U.S. Department of Education, the Supreme Court granted a stay pending appeal of D. Mass’s TRO blocking the government’s termination of education grants.
  • April 9: In State of California v. U.S. Department of Education, D. Mass. terminated plaintiff’s motion for preliminary injunction as moot in light of plaintiffs’ notice of withdrawal following the Supreme Court’s decision to grant a stay pending appeal of the TRO.
  • April 10: In Chicago Women in Trades v. Trump, N.D. Ill. held a hearing on plaintiff’s motion for preliminary injunction, and extended its TRO through April 17, 2025.
  • April 14: In Chicago Women in Trades v. Trump, N.D. Ill. partially granted plaintiff’s motion for a preliminary injunction, via a memorandum opinion and order enjoining the Department of Labor “from requiring any grantee or contractor to make a certification pursuant to section 3(b)(iv) of [EO] 14173” and “from applying section 2(b)(i) of [EO] 14151 against [the plaintiff] to prevent termination of its Women in Apprenticeship and Nontraditional Occupations grant.”
  • April 15: In Chicago Women in Trades v. Trump, N.D. Ill. issued an order on plaintiff’s motion for preliminary injunction.

3. Energy and Environment

  • April 8: President Trump issued a number of actions related to energy and the environment:
    • EO 14261, “Reinvigorating America’s Beautiful Clean Coal Industry and Amending Executive Order 14241,” which, among other things, directs the Chair of the National Energy Dominance Council to designate coal as a “mineral” within the meaning of EO 14241; directs a report assessing the impediment of mining coal resources and reserves on federal lands; and directs the identification of regions where coal-powered infrastructure is available to support AI data centers.
    • EO 14260, “Protecting American Energy from State Overreach,” which directs the Attorney General to identify and stop the enforcement of state and local laws burdening domestic energy resources “that are or may be unconstitutional, preempted by Federal law, or otherwise unenforceable.” 
    • EO 14262, “Strengthening the Reliability and Security of the United States Electric Grid,” which directs the Secretary of Energy to “streamline, systemize, and expedite the Department of Energy’s processes for issuing orders under section 202(c) of the Federal Power Act” during periods “when the relevant grid operator forecasts a temporary interruption of electricity supply is necessary to prevent a complete grid failure.”  It further directs the Secretary of Energy to “develop a uniform methodology for analyzing current and anticipated reserve margins for all regions of the bulk power system regulated by the Federal Energy Regulatory Commission and shall utilize this methodology to identify current and anticipated regions with reserve margins below acceptable thresholds as identified by the Secretary of Energy.”
  • April 9: President Trump issued EO 14270, “Zero-Based Regulatory Budgeting to Unleash American Energy,” which aims to rescind unnecessary energy-regulated regulations.
    • For more details on the “Zero-Based Regulatory Budgeting” EO, and several other executive actions promulgated on the same day, see our overview here.
  • April 15: In Woonasquatucket River Watershed Council v. USDA, a case brought by nonprofits challenging the freeze of Inflation Reduction Act (“IRA”) and Infrastructure Investment and Jobs Act (“IIJA”) funds pursuant to EO 14154 and Office of Management and Budget (“OMB”) memorandum M-25-11, D.R.I. issued a preliminary injunction enjoining the freeze. 

4. Trade and Foreign Aid

5. DOGE

Photo of Scott A. Freling Scott A. Freling

Scott Freling divides his practice between representing civilian and defense contractors in traditional government contracts matters and guiding buyers and sellers—including a number of leading private equity firms—through the regulatory aspects of complex government contracts M&A deals. Scott co-chairs the firm’s Government Contracts…

Scott Freling divides his practice between representing civilian and defense contractors in traditional government contracts matters and guiding buyers and sellers—including a number of leading private equity firms—through the regulatory aspects of complex government contracts M&A deals. Scott co-chairs the firm’s Government Contracts practice.

Scott is sought after for his regulatory expertise and his ability to apply that knowledge to the transactional environment. Scott has deep experience leading classified and unclassified due diligence reviews of government contractors, negotiating transaction documents, and assisting with integration and other post-closing activities. He has been the lead government contracts lawyer in dozens of M&A deals, with a combined value of more than $79 billion. This has included Warburg Pincus and Berkshire Partners’ pending deal to acquire TRIUMPH for approximately $3 billion, Advent’s acquisition of Maxar Technologies for $6.4 billion, Aptiv’s acquisition of Wind River for $3.5 billion, and Veritas Capital’s sale of Alion Science and Technology to Huntington Ingalls for $1.65 billion.

Scott also represents contractors at all stages of the procurement process and in their dealings with federal, state, and local government customers. He handles a wide range of government contracts matters, including compliance counseling, claims, disputes, audits, and investigations. In addition, Scott counsels clients on risk mitigation strategies, including obtaining SAFETY Act liability protection for anti-terrorism technologies.

Scott has been recognized by Law360 as a MVP in government contracts. He is a past co-chair of the Mergers and Acquisitions Committee of the ABA’s Public Contract Law Section.

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Photo of Jay Carey Jay Carey

Recognized by Chambers as one of the nation’s top bid protest lawyers and government contracts practitioners, Jay Carey represents clients in complex, high-stakes government procurements often worth billions of dollars. He is a co-chair of the firm’s Government Contracts practice group and a…

Recognized by Chambers as one of the nation’s top bid protest lawyers and government contracts practitioners, Jay Carey represents clients in complex, high-stakes government procurements often worth billions of dollars. He is a co-chair of the firm’s Government Contracts practice group and a co-chair of the Aerospace, Defense, and National Security industry group.

Jay has won bid protests collectively worth more than $100 billion, for clients across a range of industries — including aerospace & defense, energy, healthcare, biotechnology, cybersecurity, IT, and telecommunications. He litigates protests before the U.S. Government Accountability Office (GAO); the Court of Federal Claims (COFC); and state tribunals across the country. A list of his recent wins can be found under the “Representative Matters” tab.

In addition, Jay advises clients on compliance matters, conducts internal investigations, and defends against investigations by federal and state agencies. He also counsels clients on matters related to the formation of government contracts, including organizational conflicts of interest and the protection of intellectual property rights when entering into procurement contracts, grants, cooperative agreements, and “Other Transaction Authority” agreements with the government.

Jay serves as co-chair of the American Bar Association Public Contract Law Section’s Bid Protest Committee.

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Photo of Kayleigh Scalzo Kayleigh Scalzo

Ranked by Chambers USA among government contracts practitioners, Kayleigh Scalzo represents government contractors in bid protests and other high-stakes litigation matters with the government and other private parties. She has litigated bid protests in a wide variety of forums, including the Government Accountability…

Ranked by Chambers USA among government contracts practitioners, Kayleigh Scalzo represents government contractors in bid protests and other high-stakes litigation matters with the government and other private parties. She has litigated bid protests in a wide variety of forums, including the Government Accountability Office, U.S. Court of Federal Claims, U.S. Court of Appeals for the Federal Circuit, FAA Office of Dispute Resolution for Acquisition, federal and state agencies, and state courts.

Kayleigh a co-chair of the American Bar Association Public Contract Law Section’s Bid Protest Committee. She is also a frequent speaker on bid protest issues.

Kayleigh maintains an active pro bono practice focused on immigration issues and gender rights.

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Photo of Jennifer Plitsch Jennifer Plitsch

Jennifer Plitsch is a member of the Government Contracts Practice Group, where she works with clients on a broad range of issues arising from both defense and civilian contracts including contract proposal, performance, and compliance questions as well as litigation, transactional, and legislative…

Jennifer Plitsch is a member of the Government Contracts Practice Group, where she works with clients on a broad range of issues arising from both defense and civilian contracts including contract proposal, performance, and compliance questions as well as litigation, transactional, and legislative issues.

She has particular expertise in advising clients on intellectual property and data rights issues under the Federal Acquisition Regulations (FAR) and obligations imposed by the Bayh-Dole Act, including march-in and substantial domestic manufacturing. Jen also has significant experience in negotiation and compliance under non-traditional government agreements including Other Transaction Authority agreements (OTAs), Cooperative Research and Development Agreements (CRADAs), Cooperative Agreements, Grants, and Small Business Innovation Research agreements.

For over 20 years, Jen’s practice has focused on advising clients in the pharmaceutical, biologics and medical device industry on all aspects of both commercial and non-commercial agreements with various government agencies including:

the Department of Veterans Affairs (VA);
the Department of Health and Human Services (HHS), including the Biomedical Advanced Research and Development Authority (BARDA), the National Institutes of Health (NIH), and the Centers for Disease Control (CDC);
the Department of Defense (DoD), including the Defense Threat Reduction Agency (DTRA), the Defense Advanced Research Projects Agency (DARPA), and the Joint Program Executive Office for Chemical Biological Defense (JPEO-CBRN); and
the U.S. Agency for International Development (USAID).

She regularly advises on the development, production, and supply to the government of vaccines and other medical countermeasures addressing threats such as COVID-19, Ebola, Zika, MERS-CoV, Smallpox, seasonal and pandemic influenza, tropical diseases, botulinum toxin, nerve agents, and radiation events. In addition, for commercial drugs, biologics, and medical devices, Jen advises on Federal Supply Schedule contracts, including the complex pricing requirements imposed on products under the Veterans Health Care Act, as well as on the obligations imposed by participation in the 340B Drug Pricing program.

Jen also has significant experience in domestic sourcing compliance under the Buy American Act (BAA) and the Trade Agreements Act (TAA), including regulatory analysis and comments, certifications, investigations, and disclosures (including under the Acetris decision and Biden Administration Executive Orders). She also advises on prevailing wage requirements, including those imposed through the Davis-Bacon Act and the Service Contract Labor Standards.

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Photo of Lindsay Burke Lindsay Burke

Lindsay Burke co-chairs the firm’s Employment Practice Group and regularly advises U.S., international, and multinational employers on employee management and culture issues and international HR compliance. She is a key member of the firm’s Institutional Culture and Social Responsibility practice, working together with…

Lindsay Burke co-chairs the firm’s Employment Practice Group and regularly advises U.S., international, and multinational employers on employee management and culture issues and international HR compliance. She is a key member of the firm’s Institutional Culture and Social Responsibility practice, working together with white collar colleagues to conduct culture assessments, internal investigations of executive misconduct, and civil rights and racial equity audits and assessments. Lindsay has been at the forefront of the changing workplace issues impacting employers in the U.S. in the last decade, including #MeToo, Covid-19, and the renewed focus on diversity, equity, and inclusion. She frequently advises employers in relation to their processes and procedures for investigating complaints of discrimination, harassment, and retaliation and trains executive teams and board members on culture risk and the lawful implementation of DEI programs.

Lindsay also guides employers through the process of hiring and terminating employees and managing their performance, including the drafting and review of employment agreements, restrictive covenant agreements, separation agreements, performance plans, and key employee policies and handbooks. She provides practical advice against the backdrop of the web of state and federal employment laws, such as Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act, the Equal Pay Act, the Family and Medical Leave Act, the Fair Labor Standards Act, and the False Claims Act, with the objective of minimizing the risk of employee litigation. When litigation looms, Lindsay relies on her experience as an employment litigator to offer employers strategic advice and assistance in responding to demand letters and agency charges.

Lindsay works frequently with the firm’s privacy, employee benefits and executive compensation, corporate, government contracts, and cybersecurity practice groups to ensure that all potential employment issues are addressed in matters handled by these groups. She also regularly provides U.S. employment law training, support, and assistance to start-ups, non-profits, and foreign parent companies opening affiliates in the U.S.

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Photo of Michael Wagner Michael Wagner

Mike Wagner represents companies and individuals in complex compliance and enforcement matters arising in the public procurement context. Combining deep regulatory expertise and extensive investigations experience, Mike helps government contractors navigate detailed procurement rules and achieve the efficient resolution of government investigations and…

Mike Wagner represents companies and individuals in complex compliance and enforcement matters arising in the public procurement context. Combining deep regulatory expertise and extensive investigations experience, Mike helps government contractors navigate detailed procurement rules and achieve the efficient resolution of government investigations and enforcement actions.

Mike regularly represents contractors in federal and state compliance and enforcement matters relating to a range of procurement laws and regulations. He has particular experience handling investigations and litigation brought under the civil False Claims Act, and he routinely counsels government contractors on mandatory and voluntary disclosure considerations under the FAR, DFARS, and related regulatory regimes. He also represents contractors in high-stakes suspension and debarment matters at the federal and state levels, and he has served as Co-Chair of the ABA Suspension & Debarment Committee and is principal editor of the American Bar Association’s Practitioner’s Guide to Suspension & Debarment (4th ed.) (2018).

Mike also has extensive experience representing companies pursuing and negotiating grants, cooperative agreements, and Other Transaction Authority agreements (OTAs). In this regard, he has particular familiarity with the semiconductor and clean energy industries, and he has devoted substantial time in recent years to advising clients on strategic considerations for pursuing opportunities under the CHIPS Act, Inflation Reduction Act, and Bipartisan Infrastructure Law.

In his counseling practice, Mike regularly advises government contractors and suppliers on best practices for managing the rapidly-evolving array of cybersecurity and supply chain security rules and requirements. In particular, he helps companies assess and navigate domestic preference and country-of-origin requirements under the Buy American Act (BAA), Trade Agreements Act (TAA), Berry Amendment, and DOD Specialty Metals regulation. He also assists clients in managing product and information security considerations related to overseas manufacture and development of Information and Communication Technologies & Services (ICTS).

Mike serves on Covington’s Hiring Committee and is Co-Chair of the firm’s Summer Associate Program. He is a frequent writer and speaker on issues relating to procurement fraud and contractor responsibility, and he has served as an adjunct professor at the George Washington University Law School.

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Photo of Andrew Guy Andrew Guy

Andrew Guy advises clients across a broad range of government contracting issues — including regularly representing contractors in bid protests before the U.S. Court of Federal Claims and the U.S. Government Accountability Office (“GAO”).

Andrew also has extensive investigations and False Claims Act…

Andrew Guy advises clients across a broad range of government contracting issues — including regularly representing contractors in bid protests before the U.S. Court of Federal Claims and the U.S. Government Accountability Office (“GAO”).

Andrew also has extensive investigations and False Claims Act experience. He routinely assists clients in responding to Civil Investigative Demands and other government inquiries.

Before joining the firm, Andrew clerked for the Honorable Kenneth F. Ripple of the U.S. Court of Appeals for the Seventh Circuit.

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Victoria Skiera

Victoria Skiera is an associate in the firm’s Washington, DC office. She is a member of the government contracts practice group and maintains an active pro bono practice.

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Ethan Syster

Ethan Syster is an associate in the firm’s Washington, DC Office. He is a member of the Government Contracts Practice Group. Ethan assists clients with a broad range of issues across all stages of the public procurement process.

Read more about Ethan Syster