Among the most challenging areas of regulatory compliance for federal contractors are cost accounting and cost and pricing data disclosure requirements. Indeed, many companies place guardrails on the nature and scale of their business relationships with the U.S. government precisely to avoid the application of these requirements. In a move that seems consistent with the
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BIOSECURE Act Moves Closer to Enactment with Inclusion in FY 2026 NDAA Text
After failing to be included in the Fiscal Year (“FY”) 2025 National Defense Authorization Act (“NDAA”) or passed as a standalone piece of legislation, the BIOSECURE Act has moved closer to finally being enacted after it was included in the final FY 2026 NDAA text released by Congress on December 7, 2025. Section 851 of…
COFC Reaffirms Domestic Sourcing Regulations as a Viable Basis for Bid Protests
By Hunter Bennett & Eunsun Cho
Recently, in Cosette Pharmaceuticals, Inc. v. United States, the Court of Federal Claims sustained a bid protest, finding that the agency misapplied the Trade Agreements Act (“TAA”) during proposal evaluation. That decision is a helpful reminder that the Court can be a hospitable forum for challenging an agency’s application of domestic sourcing regulations.…
Top Five Trends and Takeaways from the FY 2025 ASBCA and CBCA Annual Reports
As fiscal year (“FY”) 2025 closes, both the Armed Services Board of Contract Appeals (“ASBCA”) and Civilian Board of Contract Appeals (“CBCA”) released their annual reports. Together, the two reports provide a useful snapshot of case volumes, outcomes, agency trends, and procedural developments. We break down the findings and, most importantly, what they mean for…
From DAS to WAS: Secretary Hegseth’s Acquisition Overhaul and What It Means for Industry
On November 7, 2025, Secretary of War Pete Hegseth used a speech at the National War College to unveil a Department of War (“DoW”) memorandum titled “Transforming the Defense Acquisition System into the Warfighting Acquisition System to Accelerate Fielding of Urgently Needed Capabilities to Our Warriors.” This memorandum, referred to throughout as the “WAS Memo”—formally…
“Show Don’t Tell” — GAO Stresses the Importance of Adequately Documenting OCI Investigations
As previously noted, although agency organizational conflict of interest (OCI) investigations are highly discretionary, that discretion is not boundless. GAO’s recent sustain of an impaired objectivity OCI claim in Castro & Company, LLC, B-423689, Nov. 13, 2025, underscores that point, and highlights the need for contracting officers to meaningfully consider the potential conflict…
Contractors Should Not Overlook the Administration’s Call to Action on Commerciality
Last week, Secretary Hegseth delivered a speech at the National War College introducing transformations to the defense procurement process. Among them, the Secretary discussed awarding companies bigger and longer contracts for proven systems; removing “excessive and burdensome” requirements (for example, acquisition rules, accounting standards, and testing oversight); and empowering program leaders with authority to direct…
Massachusetts Seeks to Expand Defense Footprint with Nearly $47 Million in New Projects
Massachusetts aims to be the “cornerstone of the defense industry,” with Governor Maura Healey announcing nearly $47 million in government funding for defense-related projects. Last year, the Department of Defense ranked Massachusetts ninth out of the top ten states in total Defense spending in FY2023, and the state is aiming to expand its investment in…
August, September, and October 2025 Cybersecurity Developments Under the Trump Administration
This is the seventh blog in a series of Covington blogs on cybersecurity policies, executive orders (“EOs”), and other actions of the Trump Administration. The sixth blog is available here and our initial blog is available here. This blog describes key cybersecurity developments that took place in August, September, and October 2025.
NIST Publishes…
How Will DoW Determine Which Level of CMMC Applies to My Agreement?
Now that the final Cybersecurity Maturity Model Certification (CMMC) Program and Procurement Rules have been issued by the Department of War (DoW) (see our CMMC Toolkit for in-depth analysis of these Rules) and the CMMC Program is set to begin in earnest, there is some uncertainty in industry as to how DoW will determine which…