On January 23, 2026, Vice President Vance announced the administration’s intent to expand the “Mexico City Policy.” First established by President Reagan, the Mexico City Policy originally prohibited foreign non-governmental organizations (“NGOs”) from using funds to “promote abortion as a method of family planning in other nations.” The policy was repealed by the
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Federal Push for Critical Minerals Stockpiling: 2025 in Review and Outlook for 2026
As the federal government focuses on securing reliable supplies of critical minerals, stockpiling has emerged as a key policy tool, alongside direct investments in private enterprises and expanded funding programs for industry. The National Defense Stockpile (“NDS”) currently serves as the federal strategic reserve of materials needed for national defense, including critical minerals, and the…
Pentagon Releases Artificial Intelligence Strategy
The past month has marked a series of announcements from the Department of War (the “Department”) emphasizing rapid deployment of artificial intelligence (“AI”) industry partnerships. These announcements signal opportunities for not only the defense industrial base, but also nontraditional defense contractors focused on technology and data.
On January 9, 2026, the Department released two key…
GAO’s Annual Bid Protest Report: Fiscal Year 2025 Protest Filings Drop While the Effectiveness Rate Remains High
On December 12, 2025, GAO released its Bid Protest Annual Report to Congress for Fiscal Year 2025, which provides bid protest statistics and other information regarding GAO’s protest system.…
FY26 NDAA Aims to Raise the Dollar Thresholds for the Applicability of CAS and TINA
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…
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
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…