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Building the Cyber Fortress: New Cybersecurity Executive Order Targets Quantum, AI, and Supply Chain Security

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...more

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

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)...more

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

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...more

The “Prestige”: DoD Unveils NIST SP 800-171 Revision 3, Organizationally Defined Parameters

On April 15, 2025, the Department of Defense (DoD) released official guidance on Organizationally Defined Parameters (ODPs) appearing in the newly published NIST SP 800-171 Revision 3. At the same time, the DoD reaffirmed...more

Tariffs, Leprechauns, and Contract Gold: Navigating the Hidden Costs of Trade Policies

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...more

They Did It. They Really Did It! The Arrival of the FAR CUI Proposed Rule

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...more

OMB Issues Guidance to Agencies on Responsible Artificial Intelligence Acquisitions

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...more

DOJ Went Down to Georgia: Lessons Learned from Recent Cybersecurity Enforcement Actions

Some might say there’s little difference between dealing with the devil and being a federal contractor. And for the unwary or unprepared, that may not be far off. Federal contracting comes with a litany of “fine print” that...more

NIST SP 800-171 Revision 3 Goes Final: Who’s Down with ODP?

On May 14, 2024, the National Institute of Standards and Technology (NIST) dropped the third remix…er, revision…of its Special Publication (SP) 800-171, “Protecting Controlled Unclassified Information in Nonfederal Systems...more

DoD’s Proposed CMMC Rule: Groundhog Day… or a Final Rule in the Works?

On December 26, 2023, the Department of Defense (“DoD”) belatedly gifted defense contractors and subcontractors a Proposed Rule on the Cybersecurity Maturity Model Certification (“CMMC”) Program. DoD also released eight CMMC...more

Knowing IS the Battle: Supreme Court to Address the FCA’s Scienter Standard

Scenario 1: A pharmacy chain hires a value consultant to review its Medicare and Medicaid billing practices for ways to optimize the coding of drug reimbursements to maximize profits. Drugs that had historically been charged...more

With Just a Little Ado: Significant Buy American Changes Are Coming Before Halloween

Regardless of whether they were eagerly anticipated or begrudgingly unavoidable, the changes promised to the Buy American Act (BAA) early last year have at last arrived, or at least are quickly approaching. On March 4, 2022,...more

PLAy Ball! Executive Order Directs Project Labor Agreements for Construction Projects Over $35 Million

With Spring Training just a few weeks away it looks like the Biden Administration is stepping up to the plate to ensure the plans in its $1 trillion Infrastructure Investment and Jobs Act can avoid strikes. On February 4,...more

CMMC 2.0: Throwback Cybersecurity — Everything Old Is New Again

After months of review, on November 4, 2021, the Department of Defense (DoD) finally unveiled its new version of the Cybersecurity Maturity Model Certification (CMMC 2.0). Well, almost. In a blink-and-you’ll-miss-it moment,...more

The Clauses Implementing Vaccination Mandate for Federal Contractors Are Out—Key Considerations for Contractors

Four memoranda, released in the last several business days, provide federal contracting officers guidance and suggested clauses to implement President Biden’s Executive Order 14042 (the Executive Order) in federal contracts...more

Office Closures And Limited Access: Federal Contractor Considerations When Weathering Potential Political Unrest

As has been widely reported, the United States Federal Bureau of Investigation is warning of mass protests and potential violence accompanying the inauguration of President-Elect Joe Biden on January 20, 2021. However, unlike...more

The FAR Council’s Second Interim Rule Implementing NDAA Section 889(a)(1)(B): And The Hits Keep Coming!

Like the hits produced by DJ Khaled, the FAR Council offers “another one.” As covered extensively in this blog, federal contractors have been—or should have been (you have been working toward compliance, haven’t...more

Risks, Reefs, and Wrecks: Charting A Course Through The Perils Of Covered Telecommunications Equipment And Services

Like the sailors of old, the government contracting community ventures forth knowing full well that danger lies ahead – although fortunately not in the form of a kraken, leviathan, or other mythical sea monster. Rather,...more

Gambling On Compliance? DOJ Updates The House Rules On Corporate Compliance Program Expectations

When entering a casino, professional gamblers understand that “the house doesn’t beat the player. It just gives him the opportunity to beat himself.” This axiom is precisely why in the long run casinos make money, while...more

Update On The COVID-19 Federal Contractor’s Guide – The Office Of Management and Budget Issues Critical Guidance Regarding Federal...

On Friday, March 20, 2020, the Office of Management and Budget (OMB) issued Memorandum No. M-20-18, titled “Managing Federal Contract Performance Issues Associated With The Novel Coronavirus (COVID-19).” The Memorandum,...more

Let Me Clear My Throat: DCAA Course Corrects on “Expressly Unallowable” Costs

Cough…cough…ahem…cough… Any contractor who has had the misfortune of dealing with the Defense Contract Audit Agency (DCAA) likely knows all too well that the agency is the Will Rogers of costs – it never met a cost it didn’t...more

Contractors In The Crosshairs – Weathering The 2019 Government Shutdown

Here we are again. Large swaths of the federal government have been closed since December 22 because Congress and the president cannot agree on legislation to fund the government. Nearly a million federal employees are not...more

Government Contractors Should Not Fear Contract Termination Over Twitter #ComplicatedRegulations #CostlyTerminationProvisions

Carrier. UTC. Boeing. Swamp-draining rhetoric. While many ponder what America can expect from the next administration, one thing is clear – it appears to have its eyes on government contractors. However, it is important for...more

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