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
U.S. Department of Commerce Opens New Funding Opportunity for Semiconductor R&D
The Department of Commerce recently released a new funding opportunity to support semiconductor-related research and development using funds appropriated under the CHIPS Act of 2022 (Pub. L. No. 117-167, 136 Stat. 1366 (Aug. 9, 2022)). Set forth below are a few key considerations that interested applicants should bear in mind when evaluating this opportunity, including…
Overhauling the GSA Schedule
On October 17, 2025, the General Services Administration (“GSA”) announced that it plans to issue a Mass Modification to GSA’s Multiple Award Schedule (“MAS” or “Schedule”) Solicitation[1] and Schedule contracts in November 2025 (“Refresh”). Periodically, GSA may issue a Mass Modification to Schedule contracts to uniformly impose changes to the contract terms applicable to…
JCIDS, Rewired: What DoD’s New Requirements Memo Means
On August 20, 2025, the Department of Defense (“DoD”) issued a sweeping memo that tears up and rebuilds the way the military decides what new weapons and systems it needs. The Military Services appear to be wasting no time translating the memo into action. Acquisition leaders at last week’s Association of the United States Army…
Expired: SBIR/STTR and DPA Authorities in Limbo
Two cornerstone authorities for federal contracting quietly expired on September 30, 2025, creating ripple effects that contractors—small and large—cannot afford to overlook. The Small Business Innovation Research/Small Business Technology Transfer (“SBIR/STTR”) programs, commonly known as “America’s Seed Fund” for their role in fueling early-stage innovation, and the Defense Production Act (“DPA”), the backbone of the…
Revolutionary FAR Overhaul Seeks to Make Post-Award, Agency-Level Protests More Enticing
As part of the Trump Administration’s Revolutionary FAR Overhaul[1] (“RFO”), the FAR Council has released a model deviation for FAR Part 33 – Protests, Disputes, and Appeals, which includes changes that seem intended to make agency-level protests more appealing to disappointed offerors. It remains to be seen whether these proposed changes will have the…
E-Verify and the False Claims Act: An Emerging Tool in Immigration Enforcement
On September 18, 2025, the Department of Justice (“DOJ”) announced a civil False Claims Act (“FCA”) settlement against a New Jersey shipbuilder to resolve allegations that it improperly employed unauthorized workers to work on Navy ships. The settlement, which exceeded $4 million, is the second this year involving government contractors alleged to have employed…
First Order Issued under the Federal Acquisition Supply Chain Security Act, Triggering Immediate Requirements on Contractors
On September 15, 2025, the Office of the Director of National Intelligence (“ODNI”) issued the first public exclusion and removal order (the “Order”) under the framework established by the Federal Acquisition Supply Chain Security Act of 2018 (“FASCSA”). The Order applies to all products and services produced or provided by Acronis AG as well as…
En Banc Decision in Percipient.ai, Inc. v. United States: Federal Circuit Holds That Only Actual or Prospective Bidders or Offerors Have Bid Protest Standing Under Tucker Act
This blog previously covered the Federal Circuit’s decision in Percipient.ai, Inc. v. United States, which addressed bid protest jurisdiction and standing at the Court of Federal Claims (“COFC”), and seemed to potentially open the door to a new category of protests. Now, in an en banc ruling, the Federal Circuit vacated that decision and reached…
Cybersecurity Maturity Model Certification (CMMC) Program Procurement Final Rule Announced
This blog post discusses the Department of Defense’s (“DoD”) new cybersecurity rule that imposes certain cybersecurity requirements on relevant DoD contractors and subcontractors. The post will be of interest to all DoD contractors, subcontractors, and possibly affiliates of contractors that may be impacted by the new rule’s cybersecurity requirements.
On September 10, 2025, DoD published…