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
CAS Madness Takes Its Toll: The Detailed Work of Conforming CAS to GAAP
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
Viva ‘Contractification’: New Executive Order Promises Changes to Grant Oversight
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
New “Unlawful Discrimination” Guidance from DOJ Underscores Risks to Federal Grant Recipients
Earlier this year, we addressed a growing sense of confusion and unease among federal contractors relating to shifting diversity, equity, and inclusion (DEI) standards. Specifically, awardees had to take stock of the Department of Justice’s (DOJ) newly launched Civil Rights Fraud Initiative. DOJ explained that it intended to pursue False Claims Act (FCA) cases against “any recipient of federal funds that knowingly violates federal civil rights law,” with an emphasis on unlawful DEI workplace programs. But given this year’s abrupt shift regarding DEI standards, contractors were left to guess which conduct could put them in DOJ’s crosshairs. On July 29, DOJ elaborated on what it considers “unlawful discrimination,” issuing Guidance for Recipients of Federal Funding Regarding Unlawful Discrimination (“Guidance”) to all federal agencies. The Guidance outlines what DOJ deems “best practices” so that any organization that receives federal financial assistance—e.g., universities, local governments, and nonprofit organizations—can take practical steps “to minimize the risk of violations.”Continue Reading New “Unlawful Discrimination” Guidance from DOJ Underscores Risks to Federal Grant Recipients
In the Wake of High-Profile Terminations of Grants and Cooperative Agreements, Courts Begin to Weigh In
Over the past few months, the second Trump administration has taken quick actions to suspend and terminate federal awards predating the transition of power. Many of these actions have resulted in the termination of “federal financial assistance”—specifically, grants and cooperative agreements. Organizations that have seen their grants and cooperative agreements terminated have pushed back through the courts with varying success, contending that agencies have acted arbitrarily in violation of the Administrative Procedure Act (APA). While there are many cases, this post provides an overview of three recent decisions in this rapidly developing landscape:Continue Reading In the Wake of High-Profile Terminations of Grants and Cooperative Agreements, Courts Begin to Weigh In