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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

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

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…

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

“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

In Part I of this series we introduced readers to what Controlled Unclassified Information (CUI) is understood to consist of under the CUI Program at 32 CFR pt. 2002, differentiating and safeguarding CUI, CUI Program Authority and Control, and CUI policy as promulgated under the U.S. Department of Defense CUI Program. (See 66 GC ¶…

The U.S. Department of Defense’s Cybersecurity Maturity Model Certification (CMMC) Program will become operational at some point in fiscal year 2025. In October, the DOD issued a Final Rule to address evolving cybersecurity requirements and cyber threats while defining the security controls that DOD intends defense contractors and subcontractors to implement. The program will require…