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Cara Wulf

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The FY2026 National Defense Authorization Act (NDAA) became law on December 18, 2025, enacting a tidal wave of the Trump administration’s priorities with respect to Department of Defense (DoD) procurement. One key priority reflected in the NDAA is reducing compliance burdens so that (i) established DoD contractors are incentivized to pursue awards and (ii) more companies opt in to being a DoD contractor to grow the industrial base. Importantly, Section 1804 and Section 1806 of the NDAA take action on this priority by raising the dollar thresholds for complex domains of government contracting: the Cost Accounting Standards (CAS) and submission of certified cost or pricing data. While these changes are welcome developments, companies should be cognizant that a steady stream of compliance requirements remains even with these increased thresholds.Continue Reading Swept Away: FY2026 NDAA Updates to CAS and Certified Cost or Pricing Data Thresholds

Drumroll, please. On November 7, 2025, the Department of Defense (DoD) released three memoranda signaling changes to its approach to procurement and Foreign Military Sales/Direct Commercial Sales in the years to come: “Unifying the Department’s Arms Transfer and Security Cooperation Enterprise to Improve Efficiency and Enable Burden-Sharing”; “Reforming the Joint Requirements Process to Accelerate Fielding of Warfighting Capabilities”; and “Transforming the Defense Acquisition System into the Warfighting Acquisition System to Accelerate Fielding of Urgently Needed Capabilities to Our Warriors.” The latter memorandum appends the DoD’s Acquisition Transformation Strategy (the Strategy), which is aimed at dramatically reforming how the DoD’s acquisition system operates with an eye toward increasing the speed and flexibility of DoD procurements and the acquisition workforce. This document begins the march toward sunsetting the existing Defense Acquisition System in favor of what is envisioned to be a more rapid and effective system designed to provide the DoD with the capabilities it needs to meet its mission requirements.Continue Reading The Drumbeat of Progress: DOD’s Acquisition Transformation Strategy

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

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

Sequels are rarely better than the films that precede them, and yet, sometimes a story is just too compelling to be limited to just one film. At the tail end of a summer full of Hollywood sequels, the Department of Defense (DoD) released a long-gestating sequel of its own. On August 15, 2024, DoD published a Proposed Rule that would revise the DoD Federal Acquisition Regulation Supplement (DFARS) to implement Cybersecurity Maturity Model Certification (CMMC) 2.0 into DoD contracts in the near(ish) future. This follows a December 2023 Proposed Rule, discussed here, establishing the CMMC 2.0 requirements in broad strokes. In this latest Proposed Rule, DoD proposes several changes to the DFARS that would do the following:Continue Reading CMMC and DFARS 252.204-7021—Is the Sequel Better than the Original?

DOD released a final rule which updates the DFARS to address requirements outlined in Executive Order 14005, “Ensuring the Future is Made in All of America by All of America’s Workers.” Cara Wulf and Marcos Gonzalez explain the changes and what contractors should be aware of while making adjustments to their supply chains in order…

Just in time for the season of new backpacks, lunch boxes, and school supplies, the Office of Management and Budget (OMB) has assigned some homework to contractors looking to participate in Federal financial assistance programs for infrastructure. Consistent with its Build America, Buy America Act (BABA) mandates, on August 23, 2023, OMB published a Final Rule revising its Guidance for Grants and Agreements to implement BABA (Final Rule). This Final Rule follows the Proposed Rule of February 9, 2023 (Proposed Rule), which we previously discussed, in which OMB proposed creating a new part 184 in 2 Code of Federal Regulations (CFR), and revising 2 CFR 200.322, Domestic preferences for procurements, to implement the requirements in Section 70914 of BABA. With the guidance becoming effective October 23, 2023, contractors should not put off studying these requirements if they want to be prepared for the BABA tests that will undoubtedly come as agencies begin to implement this guidance.Continue Reading Back to School: Time to Study the OMB Final Rule Implementing BABA

On June 2, 2023, the FAR Council issued an Interim Rule to implement the prohibition on having or using TikTok or any successor application or service developed or provided by ByteDance Limited (covered application). Importantly, the prohibition applies not only to Government-issued devices but encompasses contractor and contractor employee-owned devices (e.g., employee devices used as part of a bring-your-own-device program) as well. The Interim Rule took immediate effect and requires new FAR clause FAR 52.204-27, Prohibition on a ByteDance Covered Application, to be included in solicitations issued on or after June 2, 2023. In addition, solicitations issued before the effective date were required to be amended by July 3, 2023, provided that award of the resulting contract(s) occurs on or after the effective date. Existing indefinite-delivery, indefinite-quantity contracts were required to be modified to include the new clause by July 3, 2023, to apply to future orders. Finally, if exercising an option or modifying an existing contract to extend the period of performance, contracting officers must include the clause. In short, this clause will soon be in most if not all Federal government contracts. Contractors should take action now to ensure that they are prepared to comply with these requirements and that employees are familiar with and trained regarding the prohibition.Continue Reading TikTok Dances Off of Contractor IT Devices—Interim Rule Prohibits ByteDance Limited Applications