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CICA Stay Preserved: COFC Rules in Favor of Protester, Applies Equitable Tolling

The Competition in Contracting Act (CICA) of 1984 establishes a procedure that effectively pauses performance of a federal contract award during a bid protest. If a disappointed bidder files a protest with the Government...more

GAO Holds that Enhanced Debriefing Timing Regulations Control Over Agency Instructions

Timing is everything when it comes to bid protests at GAO. There is a mountain of GAO case law dismissing untimely protests. Contractors must strictly follow GAO’s regulations to avoid that fate and obtain a Competition...more

CDA Claim Management Primer: Suspension of Work (FAR 52.242-14)

Federal construction contracts often involve unforeseen delays. The key question is who is responsible for the resulting costs. A new decision from the ASBCA provides a blueprint for how contractors can maximize recovery...more

Beyond Dollars: COFC View on Declaratory Relief Makes Room for CPARS Litigation

Federal contractors understandably associate litigation at the Court of Federal Claims (COFC) with recovering monetary damages. Appealing denied claims to the COFC (along with the Boards of Contract Appeals) is the exclusive...more

Bid Protest Insights – Understanding Price Realism in Compensation Plans

Price realism challenges stand out as a common basis for bid protests in federal procurements. A competitor’s unrealistically low pricing may signal a lack of understanding or commitment to contract performance. Price...more

New GAO Decision Highlights Effective OCI Identification and Mitigation Practices

Federal contractors need to be proactive about detecting and neutralizing or mitigating Organizational Conflicts of Interest (OCI). The FAR’s OCI provisions (currently found at FAR Subpart 9.5) promote the fairness and...more

Update: FAR 2.0 Rollout Underway

In what is sure to be an on-going series, we have the latest update regarding the FAR 2.0 rollout. Releasing the First Rollout- On May 2, 2025, the FAR Council released substantive rewrites of FAR Parts 1 (Federal...more

Protesting Key Personnel – When to Pounce on a Bait-and-Switch

GAO just sharpened the distinction between winning and losing protest arguments related to key project personnel. The issue turns on the question of whether the winning proposal included “material misrepresentations” – and...more

The Push Towards FAR 2.0 – Interpreting the Most Recent Trump Executive Orders

The federal procurement landscape continues to shift and transform. Two recent executive orders push the government contracting community further towards the plan for a comprehensive update of the Federal Acquisition...more

Lesson Learned: Board Holds that Only the Contracting Officer Can Bind the Government

Most government contracts include a Changes clause (notably, FAR 52.243-1), which grants the Government the right to order changes to the scope of the contractor’s work. That clause also entitles the contractor to an...more

How to Protest an Agency’s Decision Canceling a Solicitation

The general rule (FAR 14.404-1(a)) is that – once a solicitation is put out for bid – the agency must award the contract to the responsible bidder with the lowest responsive bid. However, as is usually the case, there are...more

Highlights from our Fourth Annual Federal Contracts Symposium

We invite you to review the materials from our presentations that covered key issues facing government contractors. The topics include: • Year in Review – Federal Contracts Case Law Update- • Cost Accounting Compliance-...more

Trade Associations Urge the White House for a Pragmatic Regulatory Landscape Concerning the Build America, Buy America (BABA)...

Early this month, several electrical trade associations urged the Biden administration to implement pragmatic BABA rules. In the letter sent to the Senior Advisor and Infrastructure Coordinator at the White House, the...more

CDA Claims: Delay Damages for an Early Finish?

One of the most common concerns for federal contractors is delay. Projects can fall behind schedule for a variety of reasons that are outside of the contractor’s control (government-directed changes, differing site...more

SBA OHA Rejects Unique Ostensible Subcontractor Affiliation Defense

Small business government contractors are (or should be) aware of the SBA’s affiliation rules. In a nutshell, the rules set the standard for whether/when another business controls – or has the ability to control – the small...more

CDA Claim Series Wrap Up: Best Practices for Government Contactors

This is the eighth (and last) of an eight-part series addressing cutting-edge strategies for Certified Claims under the Contract Disputes Act (CDA). Certified Claims are the primary avenue available to government contractors...more

Challenging CPARS Performance Evaluations through the Contract Disputes Act

This is the seventh of an eight-part series addressing cutting-edge strategies for Certified Claims under the Contract Disputes Act (CDA). Certified Claims are the primary avenue available to government contractors to...more

Handling Subcontractor Pass-Through Claims Under the CDA

This is the sixth of an eight-part series addressing cutting-edge strategies for Certified Claims under the Contract Disputes Act (CDA). Certified Claims are the primary avenue available to government contractors to recover...more

Contractor vs. Government Controversies Not Subject to the CDA

The CDA has a reputation as a “catchall” for disputes between federal contractors and the government – and to a certain extent that reputation makes a lot of sense. As I’ve been covering in this series, contractors can...more

CDA Claims vs. Requests for Equitable Adjustment

So, if you are owed time and money on a contract, should your next move be a CDA Claim or an REA? There is no one-size-fits-all answer – and contractors should carefully consider their own unique circumstances before...more

Practical Litigation Strategies for CDA Claims

This is the third of an eight-part series addressing cutting-edge strategies for Certified Claims under the Contract Disputes Act (CDA). Certified Claims are the primary avenue available to government contractors to recover...more

Essential Elements of CDA Claims – Tips and Latest Trends

Federal contractors that experience government-caused increases to the cost/time of performance have a direct route for seeking an adjustment to their contract – the Contract Disputes Act (CDA)....more

Accessing Remedy Granting Clauses under the Contract Disputes Act

This is the first of an eight-part series addressing cutting-edge strategies for Certified Claims under the Contract Disputes Act. Certified Claims are the primary avenue available to government contractors to recover...more

Past Performance Upgrade for Small Businesses Results in Additional Compliance Requirement for Large Contractors

A newly published Small Business Administration Final Rule provides small businesses with two new ways to satisfy Past Performance requirements when competing for federal prime contracts. The Rule takes effect on August 22,...more

Small Business Compliance Due Diligence Leads to Reduced FCA Penalty

Earlier this month, the Department of Justice (DOJ) announced a $5.2 million civil settlement agreement to resolve small business set-aside fraud allegations against an aerospace contractor. While the $5+ million...more

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