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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

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

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

For those who grew up gripping a joystick and dodging alien fire in Defender, riding ostriches through floating platforms in Joust, or crossing a hectic freeway in Frogger, winning wasn’t about memorizing rules; it was about adapting fast, reading the patterns, and leveling up. That same urgency now applies to federal information and communication technology (ICT) contractors. A sweeping overhaul of FAR Part 39 has just been released, and while it may not blink and beep like a cabinet in a darkened arcade, it’s just as demanding. There’s no attract mode here. The game has already started.Continue Reading FAR 2.0 Part 39 in Arcade Mode—How Federal IT Acquisition Just Hit Reset

On June 6, 2025, President Trump issued a new executive order, “Sustaining Select Efforts to Strengthen the Nation’s Cybersecurity and Amending Executive Order 13694 and Executive Order 14144” (EO), signaling the construction of a fortified cyber defense across federal operations. This directive updates the nation’s digital stronghold, modernizing risk management, defending against quantum and artificial intelligence (AI) threats, and drawing sharper lines in the battle against foreign cyber adversaries. For technology companies and federal suppliers, this is a clarion call to reinforce their digital walls and sharpen their defenses. Agencies will soon build these secure-by-design principles into every contract and procurement decision. In this era of fortress-building, failing to meet these standards not only will leave your gates unguarded but also could bar you from the entire federal marketplace. The EO may read like ordinary policy, but don’t be misled: It’s a direct command for companies to strengthen their cyber defenses or be locked out of federal opportunities altogether.Continue Reading Building the Cyber Fortress: New Cybersecurity Executive Order Targets Quantum, AI, and Supply Chain Security

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

As St. Patrick’s Day approaches, many of us are on the lookout for four-leaf clovers, a pot of gold, or perhaps even a mischievous leprechaun guarding his treasure. But in the world of government contracting, the real tricksters aren’t wearing green coats and buckled shoes—and there is no gold at the end of the procurement rainbow. Instead, that pot is full of the recently announced tariffs. Effective March 4, 2025, the Trump administration imposed 25 percent tariffs on Mexican and Canadian imports (exclusive of Canada energy imports, where there is a 10 percent tariff) and a 20 percent tariff on Chinese products. While economists, pundits, and the stock market will all have their say on the wisdom behind these actions, such prognostication is of little help to federal contractors who are forced to deal with the very real effects right now.Continue Reading Tariffs, Leprechauns, and Contract Gold: Navigating the Hidden Costs of Trade Policies

After years of anticipation, the Federal Acquisition Regulation (FAR) Council has announced the arrival of its proposed rule to enhance the safeguarding of Controlled Unclassified Information (CUI) in federal contracts (the Proposed Rule). Published in the Federal Register on January 15, 2025 (90 FR 4278), the Proposed Rule (stemming from FAR Case 2017-016) has been a long time coming and is intended to establish a government-wide standard for managing sensitive information, ensuring CUI uniformity and consistency across all agencies and federal contracts.Continue Reading They Did It. They Really Did It! The Arrival of the FAR CUI Proposed Rule

On January 8, 2025, in UNICA-BPA JV, LLC, the U.S. Government Accountability Office (GAO) sustained a protester’s challenge to its elimination from the competition for failing to have an active System for Award Management (SAM) registration at the time of its initial proposal submission. The GAO sustained the protest because the protester’s registration was in fact active at the time it submitted its final proposal revision (FPR) even though it was inactive at the time of initial proposal submission. The facts of the case are straightforward:Continue Reading What Happens When Uncle Sam Doesn’t Understand SAM? The Case of the Lucky Protester . . .