The Revolutionary FAR Overhaul (RFO) finally has moved into formal rulemaking, and it comes with a few surprises. The FAR Council completed the first phase of the RFO in September 2025, publishing model deviations to the FAR that agencies then had to adopt by issuing their own deviations and guidance. We digested the changes, organized by FAR part, here.  To begin making the FAR changes official, the FAR Council published four proposed rules[1] on June 23, 2026, covering Parts 1, 2, 3,…More

The federal government’s most sweeping cyber incident reporting mandate is approaching its final stages, and government contractors across a wide range of industries should be paying close attention. The Cyber Incident Reporting for Critical Infrastructure Act of 2022, known as CIRCIA, will require hundreds of thousands of organizations to report significant cyber incidents and ransomware payments to the Cybersecurity and Infrastructure Security Agency (CISA) on tight timelines. The new requirements are likely to disproportionately impact government contractors because of the…More

If your organization handles Controlled Unclassified Information (CUI) for the federal government, take note:  the U.S. General Services Administration (GSA) has just raised the bar on compliance. On January 5, 2026, GSA published new requirements for contractors and other nonfederal entities that work with CUI, and unlike the Department of Defense’s (DOD) phased rollout of its Cybersecurity Maturity Model Certification (CMMC) program, GSA isn’t waiting around. These requirements are effective immediately and mirror FAR proposed, but not final, CUI rule…More

When does a bidder’s failure to acknowledge an amendment to an Invitation for Bids (IFB) render the bidder nonresponsive? Generally, the FAR requires bidders to acknowledge receipt of material amendments to an IFB, but permits agencies to either allow a bidder to cure its failure to acknowledge an amendment or waive the requirement entirely where the amendment is not material to the IFB.[1] An amendment is not material if it would only have a negligible effect on price, quantity, quality,…More

On January 28, 2026, the United States Civilian Board of Contract Appeals (CBCA) issued final rulemaking to address its role in hearing and resolving disputes under the Administrative False Claims Act (AFCA), formerly known as the Program Fraud Civil Remedies Act of 1986 (PFCRA).  See 91 Fed. Reg. 3797.  The AFCA provides an alternative enforcement mechanism to the False Claims Act (FCA) for low-dollar fraudulent claims submitted to the federal government.  Under the AFCA, the boards of contract appeals may…More

The Civilian Board of Contract Appeals (CBCA) recently posted its Annual Report for Fiscal Year 2025 (FY25), which showed a significant increase in appeals but decrease in Alternative Dispute Resolution (ADR).  In FY25, the CBCA docketed a total of 390 new cases, a marked increase from 319 in FY24.  Of those 390 new cases, 222 were Contract Disputes Act (CDA) appeals, up from 165 the previous FY.[1]  Conversely, the CBCA’s ADR proceedings numbered 52, down from 73 in FY24.  This…More

On the evening of November 9, the U.S. Senate agreed to a deal aimed at ending the government shutdown.  The deal is the first step toward reopening the federal government and will now face a vote from the House of Representatives. The federal government has been shut down since October 1 after annual appropriations lapsed.  Pursuant to the Antideficiency Act, federal agencies have been prohibited from incurring obligations or expending funds without an enacted appropriation unless otherwise authorized by law. Since October…More

On July 29, 2025, US Attorney General Bondi issued a memorandum for all federal agencies titled “Guidance for Recipients of Federal Funding Regarding Unlawful Discrimination” (the Memo). The Memo follows multiple executive orders that reversed course on prior administrations with respect to diversity, equity, and inclusion (DEI) and affirmative action, and called into question set-asides for socially and economically disadvantaged small businesses. In addition, Department of Justice (DOJ) announced in a May 19, 2025, memorandum its new Civil Rights Fraud…More