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GAO Proposes Higher Pleading Standard for Bid Protests, Questions Remain for Loser-Pays Model

As we noted in a blog post in February, the 2025 National Defense Authorization Act (NDAA) was enacted in December 2024 included a provision at Section 885 raising the protest threshold for Department of Defense (DoD), Coast...more

Bid Protest Minute: Insufficient Funds are Grounds to Cancel

On April 29, the Government Accountability Office (GAO) denied Davenergy-VCI JV, LLC’s protest of a solicitation’s cancellation, holding that the lack of available funding is sufficient grounds to cancel. In denying the...more

New False Claims Act Settlement Highlights Importance of Voluntary Self-Disclosures and Due Diligence

According to an April 1 Department of Justice (DOJ) press release, DRI Relays Inc. (DRI), a subsidiary of TE Connectivity Corporation (TEC) and manufacturer of electrical relays and sockets used on military platforms, agreed...more

Bid Protest Minute: Bidder’s Responsibility to Submit Well-Drafted Proposal

On February 26, GAO denied the protest of Mission Analytics, Inc., challenging the award of a small business set-aside contract to ThunderCat Technology, LLC, explaining that “it is a firm’s responsibility to submit a...more

Department of Defense Issues Affirmative Action Class Deviation

Following U.S. General Services Administration’s (GSA) lead, which we wrote about here, on March 4, the Department of Defense (DoD) issued a Class Deviation—Restoring Merit-Based Opportunity in Federal Contracts—directing DoD...more

COFC Decision Significantly Broadens OTA Bid Protest Jurisdiction

On February 24, Judge Armando Bonilla of the Court of Federal Claims (COFC) declined to dismiss a challenge to a $648 million award under a Missile Defense Agency (MDA) development deal, finding that the court had...more

Bid Protest Minute: Understanding the Increased DoD/Coast Guard/NASA Task Order Protest Threshold

Generally speaking, the U.S. procurement system allows companies competing for U.S. government contracts broad rights to challenge contract awards, as well as the terms of solicitations. There are, however, restrictions...more

DoD Announces Cybersecurity Maturity Model Certification 2.0 Final Rule (Finally!)

After numerous fits and starts, on October 14, the Department of Defense (DoD) published a final rule implementing the Cybersecurity Maturity Model Certification (CMMC) program. Borne from documented deficiencies in the...more

DoD Publishes Proposed Rule to Amend DFARS Provisions Related to the CMMC 2.0 Program

On August 15, the Department of Defense (DoD) published a proposed rule to amend the Defense Federal Acquisition Regulation Supplement (DFARS) to incorporate contractual requirements related to the proposed Cybersecurity...more

Exception to Commercial Determination for Non-Traditional Defense Contractors Offers New Opportunities

In addition to opening the door to possible awards under the government’s Other Transactions Authority (OTA), products and services provided by contractors that meet the definition of a Non-Traditional Defense Contractor...more

Bid Protest Minute: GAO’s Task Order Jurisdiction

On December 21, the Government Accountability Office (GAO) dismissed a protest by ELS, an unsuccessful bidder on a Department of Defense (DOD) task order opportunity, concluding that it did not have jurisdiction to consider...more

Department of Defense Publishes Long-Awaited CMMC Proposed Rule

On December 26, the Department of Defense (DoD) published its long-awaited Cybersecurity Maturity Model Certification (CMMC) Program proposed rule, which places comprehensive cybersecurity and information security...more

Clarification: You Can Recover for Changes Implementing Executive Orders

The National Defense Authorization Act of 2023 includes a short but interesting provision reminding the Department of Defense (DoD) that the unilateral insertion of a new clause in a DoD contract is a change that may entitle...more

DOD’s Mentor Protégé Program Drops “Pilot” From Title as the NDAA Codifies the Initiative

On December 15, the U.S. Senate passed the National Defense Authorization Act (NDAA) for the Fiscal Year 2023 by an 83-11 vote. The annual legislation changes U.S. defense agencies’ policies and regulations and provides...more

DoD Scraps CMMC 1.0 for CMMC 2.0

For nearly two years, we have been reporting on this blog about the Department of Defense’s (DoD) Cybersecurity Maturity Model Certification (CMMC) program. CMMC is a training, certification, and third-party assessment...more

Did the Federal Circuit Just Eliminate Commercial Services?

In a decision issued on November 17, JKB Solutions v. United States, the Federal Circuit held that the commercial item termination for convenience provision at FAR 52.212-4(l) incorporated by reference into a contract for...more

The Black Hole of Protest Jurisdiction: Can I Challenge the Award of an “Other Transaction Agreement”?

While most federal procurements are conducted using the onerous regulations set forth in the Federal Acquisition Regulation (FAR) and agency supplements, agencies are increasingly relying on the more flexible, but...more

It’s Here! DoD Issues Interim Rule Launching Two Cyber Assessment Programs

For over a year, we have been discussing the Department of Defense’s (DoD) eventual implementation of a Cybersecurity Maturity Model Certification (CMMC) program for Defense contractors, most recently during a webinar in...more

DoD Issues Framework to Provide Relief to Government Contractors Affected by COVID-19-Related Closures

On April 8, the Department of Defense (DoD) issued a Class Deviation 2020-O0013 laying out the framework for implementing Section 3610 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). DoD is to be...more

Increased Progress Payments: DoD Adjusts Procurement Rules to Increase Liquidity

While the health of our citizens is, as it must be, the primary focus of the response, Congress and the Executive Branch are scrambling to ensure that companies have sufficient liquidity to continue operations, and continue...more

DoD Finalizes Cybersecurity Maturity Model Certification

The Department of Defense (DoD) has now finalized its new cybersecurity standards, which we discussed last year. The new cybersecurity standards, which are intended to protect controlled unclassified information, will be...more

DoD Implements Statutory Restrictions on LPTA Evaluations

As we noted in a blog post in December 2016, “LPTA Out, Fixed Price Contracts In,” the Department of Defense (DoD) has been moving to restrict the Lowest Price Technically Acceptable (LPTA) evaluation methodology, which...more

If You Don’t Do the Work, You Might Do Time Instead: Service-Disabled Veteran Faces Jail Time for Failing to Run Day-to-Day...

The Government recently indicted an Army veteran for allegedly using his status as a service-disabled veteran to help a company qualify as a service-disabled veteran-owned small business and falsely obtain nearly $40 million...more

Large Contractors – Time to Take Your Protests to Court?

Congress recently concluded the conference on the 2018 National Defense Authorization Act (NDAA), resolving the differences between the House and Senate versions of the FY18 NDAA passed earlier this year. Pilot Program...more

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