Executive Orders & Policy Actions

The Department of Defense (DoD) is revving its engines again—this time to rocket past its own software acquisition drag. Launched via an April 24 memo from Acting DoD CIO Katie Arrington, the DoD’s Software Fast Track (SWFT) Initiative entered a 90‑day sprint to redefine Accelerating the Authority to Operate (ATOs), aiming to replace the outdated Risk Management Framework (RMF) with AI‑enabled, continuous compliance workflows. Officially live on June 1, 2025, SWFT isn’t a fully cleared runway—it’s a mission in motion, with Requests for Information (RFIs) out and industry poised to respond. But the real turbulence won’t be technical—it’ll be cultural: Can Pentagon policy and personnel move at Top Gun pace?

Continue Reading The Need for Speed: DoD’s “Software Fast Track” Targets Bureaucracy at Mach 2

On April 15, 2025, President Trump issued a sweeping executive order (EO), “Restoring Common Sense to Federal Procurement.” As reflected in its accompanying Fact Sheet, the EO promises to rewrite the Federal Acquisition Regulation (FAR), eliminate most non-statutory provisions, and usher in the “most agile, effective, and efficient procurement system possible.” As the first comprehensive overhaul of the FAR in its nearly 40-year history, the forthcoming changes may dramatically reshape how businesses of all stripes engage with the federal government. But beyond its big promises and patriotic flair, the proposed overhaul raises critical questions: Can it really be done in six months? What happens to the thousands of existing regulations around which contractors have built compliance programs?

Continue Reading Hold My Beer: The Trump Administration’s Bold Plan to Rewrite the FAR

In recent months, federal contractors have seen an uptick in very specific types of contracting activity. As a result of various Executive Orders and DOGE directives for agencies to conduct contract reviews and engage in mass contract cancellations, there has been a flurry of terminations for convenience, suspensions/stop-work orders, and contract modifications. Payments—even those undisputedly…

In recent months, federal contractors have seen an uptick in very specific types of contracting activity. As a result of various Executive Orders, and DOGE directives for agencies to conduct contract reviews and engage in mass contract cancellations, there has been a flurry of terminations for convenience, suspensions/stop-work orders, and contract modifications. Payments—even those undisputedly…

Another day, another executive order (EO) that will transform federal procurement as we know it. A March 20, 2025 EO entitled “Eliminating Waste and Saving Taxpayer Dollars by Consolidating Procurement” and its accompanying fact sheet call for “[c]onsolidating domestic Federal procurement in the General Services Administration” (GSA), at least with regard to “common goods and services.” 

Continue Reading Executive Order Aims to Consolidate Procurement of Broadly Defined ‘Common Goods and Services’, All IT GWACs, under GSA

As the second Trump administration reaches its 60-day mark, it is a good time to take stock of the US antitrust agencies’ actions. The Federal Trade Commission (FTC) and the Department of Justice Antitrust Division (DOJ) have been busy despite the broader government shakeup. Enforcement patterns are emerging. For example, FTC Chairman Andrew Ferguson has been transparent about his priorities—health care, technology platform dominance, and labor. As the timeline below shows, he has wasted no time in implementing initiatives and enforcement in these areas. As for the DOJ, Assistant Attorney General Abigail Slater was sworn in last week, and her enforcement priorities will likely take more shape in the coming 60 days. The DOJ, however, has remained active, especially in the Sherman Act enforcement space.

Continue Reading Antitrust in Trump 2.0—the First 60 Days

Well, it is certainly an interesting time to be a federal government contractor. In the last few weeks, we have seen Executive Orders (EOs) flying fast and furious, and a lot of other activity impacting federal government contractors. Overall, these various new developments have resulted in a flurry of contract modifications, suspensions, and terminations for…

On February 26, 2025, the White House issued another Executive Order (EO) that will have major implications for Federal government contractors across numerous industries and agencies. The new EO, entitled Implementing the President’s “Department of Government Efficiency” Cost Efficiency Initiative, requires every agency to work with that agency’s DOGE Team Lead (i.e., the leader of the DOGE Team at each agency, as defined in Executive Order 14158) to, among other things, conduct a review of covered contracts and grants, set up guidance for new contracts aimed at promoting efficiency and the Trump administration’s priorities, and build a system to track and justify payments made to contractors. What does that mean for you? Consider the below.

Continue Reading New EO Demands Agencies Conduct Review of All Covered Contracts and Grants, Terminate or Modify To Reduce Spending, and Set Up System To Track and Justify All Future Payments

Amid a flurry of executive orders starting his second administration, President Donald Trump issued an order entitled “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” (the “Order”) on January 21, 2025. The Order will have an immediate impact on federal contractors and subcontractors currently subject to the affirmative action obligations concerning women and minorities under now-revoked Executive Order 11246 dated September 24, 1965 (and the subsequent executive orders that refined these obligations). It also signals a significant change in the focus of federal enforcement of equal opportunity laws. The Order does NOT, however, change any of the substantive federal law regarding employment discrimination. Under Title VII of the Civil Rights Act of 1964, it remains illegal for employers to make employment decisions on the basis of race, color, religion, sex, or national origin. Other federal and state statutes prohibit making employment decisions on various other bases, including age, disability, genetic make-up, etc.; none of these substantive laws have been changed. So what has changed?

Continue Reading DEI, Discrimination, Affirmative Action and More: How the Recent Executive Order Impacts Private Employers

Contractors interested in offering federal agencies artificial intelligence (AI) can now glean insight into how agencies are expected to conduct AI acquisitions. On September 24, 2024, the Office of Management and Budget (OMB) issued Memorandum M-24-18, Advancing the Responsible Acquisition of Artificial Intelligence in Government (the Memorandum), providing guidance and directing agencies “to improve their capacity for the responsible acquisition of AI” systems or services, including subcomponents. The Memorandum builds on the White House’s Executive Order 14110, Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence, and OMB Memorandum M-24-10, Advancing Governance, Innovation, and Risk Management for Agency Use of Artificial Intelligence. Taking effect on March 23, 2025, M-24-18 will apply to all solicitations and contract option exercises for AI systems covered under the Memorandum.

Continue Reading OMB Issues Guidance to Agencies on Responsible Artificial Intelligence Acquisitions