The Federal Acquisition Service (FAS) of the General Services Administration (GSA) revealed on October 17, 2025, that it will issue a Multiple Award Schedule (MAS) Solicitation 47QSMD20R0001 “refresh” sometime in November 2025. While GSA allowed the contracting community 10 business days to submit comments—until October 31, 2025—as MAS contract holders know, GSA issues refreshes from time to time so that changes are made uniformly in recognition of shifts in policy, regulations, or statutes. Administering MAS contracts in this way allows GSA to curate terms in a consistent manner for contractual vehicles at all stages of performance, as contractors perform orders at different times.

Continue Reading Total GSA Schedule Makeover: Incoming Mass Mod Not Merely a Refresh

This year, The Rocky Horror Picture Show celebrates the 50th anniversary of its release. While that cult classic film has stood the test of time, another relic of the 1970s, the Cost Accounting Standards (CAS), is showing its age. When CAS was initially promulgated, Congress determined that the generally accepted accounting principles (GAAP) were not enough to satisfy the government’s requirements for evaluating contract costing and pricing. However, in the decades since, GAAP has evolved, and there are now areas of overlap that have arisen since CAS was first promulgated. Recognizing this overlap, the government has set in motion a review to determine which parts of CAS could be addressed by GAAP, which is the commercial standard regularly used by companies. If there were accounting areas where GAAP could stand in place of CAS, the government wants to reduce the overall burden in the procurement process by allowing contractors to more heavily rely on GAAP, which they are already using to report on their daily business activities.

Continue Reading CAS Madness Takes Its Toll: The Detailed Work of Conforming CAS to GAAP

Here we are again. With federal funding for fiscal year 2025 lapsed, all government contractors now face potential stop work orders and financial disruptions. Below are key considerations and steps to mitigate potential risk and maximize cost recovery:

Continue Reading Key Steps for Government Contractors During the Federal Shutdown

The DoD has finally crossed the CMMC finish line, but for contractors, the race is just beginning. With the Final Rule effective Nov. 10, award eligibility will hinge on a “current” CMMC status in SPRS, backed by annual affirmations and strict compliance. The next two months are critical for getting race-ready. In this Featured Comment for The Government Contractor, Alex Major provides practical guidance to help defense contractors prepare for what lies ahead.

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Government procurement is essential to modern governance. But when firms rig bids, allocate markets, or otherwise collude, taxpayers pay more, honest competitors are shut out, and trust erodes. In recent months, US agencies have continued to emphasize the importance of fair competition in government procurement, scrutinizing regulations that may favor incumbents or unfairly limit competition and expanding whistleblower options.

Continue Reading Rigging the Game? Antitrust Risks in the Public Contracting Arena

As we have previously covered in this blog, as a result of President Trump’s executive order, Restoring Common Sense to Federal Procurement, the Federal Acquisition Regulation (FAR) is undergoing an extensive and unprecedented rewrite. While many of us were enjoying the relaxation of summer days (drifting away to summer nights), the Trump administration has been busy issuing rolling updates to the FAR, which are poised to dramatically reshape the federal acquisition landscape. On August 14, 2025, the FAR Council told us more (told us more) by issuing draft revisions to FAR Parts 4, 8, 12, and 40. The revisions to FAR Part 12 are particularly noteworthy, as they go to the heart of the executive order’s policy statement that the federal procurement system should be “agile, effective, and efficient” and that “undue barriers” should be removed from federal procurement.

Continue Reading Summer Sun, Something’s Begun, But (Oh, Oh) Those FAR Part 12 Rewrites

July’s “Winning the Race: America’s AI Action Plan,” released by the White House, contains helpful recommendations for the energy sector as the use of AI becomes more prevalent and, with it, the need for more energy. The plan recommends the use of an existing consultation and coordination process for expediting the federal permitting and review of large infrastructure projects to cover all eligible data center and data center energy projects. It also recommends optimizing existing grid resources, prioritizing the interconnection of reliable power sources, ensuring sufficient generation exists to support data centers, and embracing new technology and sources of energy.

Continue Reading Power Up: What the AI Action Plan Means for the Energy Sector

New rules for grants requiring a convenience termination
And limiting costs for facilities and administration
And if you want these kind of dreams, it’s Contractification[1]

In its continuous drive to alter business as usual, the federal government has made many changes this year to the way it manages financial assistance (grants and cooperative agreements). Executive Order 14332, “Improving Oversight of Federal Grantmaking” (the EO), issued on August 7, 2025, is the latest expression of this new effort and evidences the government’s intent to exert more control over grants and cooperative agreements. As summarized below, the changes generally fall within the inherently flexible framework the government has over such awards, but taken as a whole—and given the framing and rhetoric of the EO—the government’s approach, whether intentional or not, resembles “contractification,” that is, to remake the administration of grants and cooperative agreements to be more like procurement contracts.

Continue Reading Viva ‘Contractification’: New Executive Order Promises Changes to Grant Oversight

On July 31, 2025, the Court of Federal Claims (COFC) issued its decision in The DaVinci Company v. United States. The case is noteworthy for contractors grappling with geographical supply chain concerns because it elucidates the extent to which two cornerstone country-of-origin procurement statutes—the Buy American Act (BAA) and the Trade Agreements Act (TAA)—can be misunderstood and misapplied by the government.

Continue Reading Making Hay of the Interplay Between the TAA and BAA—COFC Sustains Protest Against the VA’s Improper Sourcing of a Critical Pharmaceutical

“Ding ding.” – Apollo Creed,
Rocky III

September 30. All (most?) federal years end the same way, at least on paper—like a prizefight, with the clock ticking down; an agitated, uncertain crowd; a lot of money on the table; and a ref capable of stopping the match at any moment. This year will be at once both no different and a completely different beast. With ever-recent uncertainty surrounding appropriations, continuing-resolution (CR) risk, evolving Federal Acquisition Regulation (FAR) language, the tightening screws of cyber attestations, industry supply-chain and acquisition changes, and grant closeouts that always take longer than you’d think, September is not a month for contractor improvisation. It’s a month when a dedicated corner team, a game plan, and crisp execution all are paramount.

Continue Reading And in This Corner … the Sweet Science of Federal Contracting’s Year-End