The US Department of Justice’s (DOJ) new Data Security Program (DSP), designed to protect sensitive information and national security-related data from misuse by foreign actors, took full effect on October 6, 2025. The program introduces new restrictions on how companies handle and share sensitive US personal data and government-related data, especially when certain foreign entities are involved. With enforcement underway, companies should understand who is covered, what activities are restricted, and what compliance measures are required. Failure to comply with the rules can result in civil or criminal penalties.

Continue Reading DOJ Launches New Data Security Program—What Your Company Needs to Know

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

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

Here we are again. With federal funding for fiscal year 2025 lapsed, all government contractors now face potential stop work orders and financial disruptions. Below are key considerations and steps to mitigate potential risk and maximize cost recovery:

Continue Reading Key Steps for Government Contractors During the Federal Shutdown

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 for The Government Contractor, Alex Major provides practical guidance to help defense contractors prepare for what lies ahead.

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Government procurement is essential to modern governance. But when firms rig bids, allocate markets, or otherwise collude, taxpayers pay more, honest competitors are shut out, and trust erodes. In recent months, US agencies have continued to emphasize the importance of fair competition in government procurement, scrutinizing regulations that may favor incumbents or unfairly limit competition and expanding whistleblower options.

Continue Reading Rigging the Game? Antitrust Risks in the Public Contracting Arena

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

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