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Defense Department Initiates Review of 8(a) and Small Business Awards (Not Just Sole-Source Awards)

In a memorandum dated January 16, 2026, the Department of Defense (DoD) has directed a department-wide review of every small business set-aside award in excess of $20 million. The Department has also ordered a review of all...more

End of an Era: State of Recertification Regulations Grace Period

The Small Business Administration (“SBA”) grace period for implementation of its new recertification regulations ended as of January 17, 2026. As we previously advised, last year SBA substantially rewrote its recertification...more

MoFo Global PE Trends 2025 and Outlook for 2026

As geopolitical unpredictability continues around the world, what does 2026 have in store for the global private equity (PE) market? In MoFo’s sixth annual Global PE Trends and Outlook report, our partners review the key...more

Is It Over Now? SBA Questions Hint at Potential Trouble for the Nonmanufacturer Rule

As small business provisions disappear from the Federal Acquisition Regulation (“FAR”) (perhaps to be relocated or perhaps to be permanently deleted) and reports of the use of a “Deregulation Tool” at the Small Business...more

Update on the FAR Overhaul

As of August 28, 2025, the project to overhaul the Federal Acquisition Regulation (FAR) has finished FAR Parts 1, 4-6, 8-12, 18, 26, 28-31, 33-36, 38-40, 43, 46, 48-51, and various sections of Parts 2 and 52. One can review...more

Federal Procurement Consolidation: OMB’s New Guidance for Greater Centralization

The Office of Management and Budget (OMB) has released new guidance in the push to consolidate federal procurement activities. The guidance, which expands on Executive Order 14240, aims to reduce waste and duplication by...more

Strengthening the American Drone Industrial Base

Buried toward the bottom of President Trump’s Executive Order, titled “Unleashing American Drone Dominance” (the “Order”), is a mandate to identify military programs made more “efficient or lethal if replaced” by unmanned...more

GAO Reaffirms Agencies’ Discretion to Award Sole-Source SBIR Phase III Contracts (Even to a Successor-in-Interest)

The Small Business Innovation Research program (SBIR) is a successful initiative that increases the participation of small business concerns in federally funded research and development. Awards under Phases I and II of the...more

Ongoing FAR Overhaul: Market Research and the New FAR Part 10

The latest part of the Federal Acquisition Regulation (FAR) to undergo a rewrite is FAR Part 10, which addresses market research for acquisitions. The General Services Administration has already adopted the new Part 10 via...more

Is Change Around the Corner? One Proposal to Forge Sweeping Changes to Defense Contracting

At the end of 2024, Senator Roger Wicker (R-MS) published a plan (“Restoring Freedom’s Forge: American Innovation Unleashed”) and introduced a bill (the Fostering Reform and Government Efficiency in Defense Act or FoRGED...more

FAR Overhaul Underway

The Federal Acquisition Regulation, initially issued on April 1, 1984, appears poised to be rewritten. Several online sources reference a GSA announcement posted on Friday, April 4, that supposedly heralded a bottom-up...more

DoD Other Transactions (OTs) Desk Reference

The incoming Trump administration has sent many signals that it intends to ramp up the Department of Defense’s use of nontraditional acquisition pathways to bridge the “Valley of Death” and bring innovative technologies to...more

Impacts to 8(a) Regulations in SBA’s New Final Rule

We continue our discussion of the Small Business Administration’s (SBA) recent final rule on various small business programs. We previously discussed SBA’s changes to the effect of recertifications under multiple award...more

Changes to SBA’s Mentor-Protégé and Joint Venture Regulations

We continue our discussion of the Small Business Administration’s (SBA) recent final rule on various small business programs. We previously discussed SBA’s changes to the effect of recertifications under multiple award...more

FAR Council Withdraws “Pay Equity and Transparency” Proposed Rule

On January 8, 2025, the Office of Federal Procurement Policy (OFPP) and the Federal Acquisition Regulation (FAR) Council withdrew a proposed rule that would have banned federal contractors and subcontractors from seeking or...more

Enforcing New Recertification Rules: Changes to SBA’s Size Protest Regulations

We continue our discussion of the Small Business Administration’s (SBA) recent final rule on various small business programs. Today, we focus on revisions to the regulations governing size protests and requests for formal...more

Less Oversight and Undefined Penalties: The NDAA’s Proposed Protest Reforms

Buried in Section 885 of the current draft of the National Defense Authorization Action (NDAA) for Fiscal Year 2025 is a new attempt to figure out how to make unsuccessful bid protesters pay. As of this posting, the NDAA has...more

The Tortured Regulations Department: SBA’s New Rule And Its Effect On Investments

In a lengthy and complex effort, the U.S. Small Business Administration (SBA) issued a final rule on December 17, 2024, that amended many requirements related to small business contracting. As with most rules, there are some...more

New DFARS Regulation On Small Business Affiliate Past Performance

Nearly a year ago, the National Defense Authorization Act for Fiscal Year 2024 directed the Department of Defense (DOD) to amend the Defense Federal Acquisition Regulation Supplement (DFARS) no later than July 1, 2024, “to...more

SBA Proposes To Require The Rule Of Two For Most Task And Delivery Order Competitions

On October 25, 2024, the Small Business Administration (SBA) published a proposed rule to mandate a Rule of Two analysis for most task and delivery order competitions, except under Federal Supply Schedule (FSS) contracts. ...more

OHA Rules Company Remains Eligible For Award Of Small Business Set-Aside Schedule Orders Even After Acquisition By A Large...

The Small Business Administration (SBA) Office of Hearings and Appeals (OHA) has yet again clarified that a company’s size change in connection with a merger-and-acquisition event generally does not prevent the company from...more

Airing Of Grievances: FAR Council Invites Novation Comments

Is it finally time to fix the outdated, incomplete, and often misunderstood novation regulations? Maybe. On April 5, 2024, the FAR Council released a Notice and Request for Comments requesting comments from federal...more

OMB Says Agencies “Should” Perform A Rule Of Two Analysis And Set Aside Requirements For Task Orders Under Multiple-Award...

The U.S. Office of Management and Budget (OMB) has issued a policy memorandum with a goal of promoting small business participation under multiple-award indefinite delivery/indefinite quantity contracts (MACs). One of the...more

GAO Finds Company's BPA Bid Remains Eligible For Award Despite A Transaction, Recertification, And Change In Size Status In...

Small business regulations create one of the stickier wickets in bid protest litigation. Although the Small Business Administration (SBA) has exclusive authority to determine a company’s size and socioeconomic status, the...more

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