As we have hinted at (and even mentioned) in some of our more recent client alerts, the proverbial other shoe has now dropped. In the April 15, 2025, Executive Order entitled "Restoring Common Sense to Federal Procurement"...more
On February 26, 2025, the Armed Services Board of Contract Appeals issued a decision allowing the government to reduce a contract by $1.1M due to a contractor’s failure to comply with the mandate to use United States-flag...more
On Monday, March 24, 2025, the General Services Administration (GSA) launched FedRAMP 20x, as an effort to automate parts of the program and create collaboration with the industry to improve authorization process for cloud...more
4/3/2025
/ Automation Systems ,
Cloud Computing ,
Cybersecurity ,
Data Security ,
FedRAMP ,
General Services Administration (GSA) ,
Government Agencies ,
Regulatory Reform ,
Regulatory Requirements ,
Risk Management ,
Technology Sector
On March 20, 2025, President Trump issued Executive Order No. 14240 titled “Eliminating Waste and Saving Taxpayer Dollars by Consolidating Procurement” (the EO).1 While less than perfectly written, it does seem to have the...more
On March 14, 2025, President Trump rescinded a second batch of Biden-era executive orders (EOs), including EO 14026 (Increasing the Minimum Wage for Federal Contractors).
Issued in 2021, EO 14026 raised the federal...more
3/20/2025
/ Biden Administration ,
Compliance ,
Department of Labor (DOL) ,
Executive Orders ,
Federal Contractors ,
Inflation Reduction Act (IRA) ,
Minimum Wage ,
Regulatory Reform ,
Rescission ,
State Labor Laws ,
Trump Administration ,
Wage and Hour
Given the impending deadline of March 14, 2025, for Congress to pass a budget or another continuing resolution (CR) (and the president signing same), coupled with the recent happenings in Washington, D.C., we thought it would...more
3/12/2025
/ Contract Terms ,
Department of Government Efficiency (DOGE) ,
Department of Labor (DOL) ,
Employees ,
Federal Acquisition Regulations (FAR) ,
Federal Budget ,
Federal Contractors ,
Federal Funding ,
Government Shutdown ,
Risk Management ,
Subcontractors
On February 1, 2025, President Trump issued Executive Order No. 14193, titled “Imposing Duties to Address the Flow of Illicit Drugs Across Our Northern Border” (Tariff EO). The EO announced tariffs that would impact a wide...more
While it is not our intent to flood your inbox with articles, alerts, and analyses; the pace, breadth, and volume of actions by the Trump administration in its first month (not even 100 days) is nothing short of remarkable....more
3/4/2025
/ Administrative Procedure Act ,
Department of Government Efficiency (DOGE) ,
Executive Orders ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Federal Funding ,
Fraud Abuse and Waste ,
Government Agencies ,
Government Efficiency ,
Regulatory Reform ,
Trump Administration
On January 15, 2025, the FAR Council finally released a proposed rule (the Rule)1 regulating the use and handling of controlled unclassified information (CUI) as a part of the general strategy to reduce threats of...more
2/21/2025
/ Compliance ,
Controlled Unclassified Information (CUI) ,
Cyber Incident Reporting ,
Cybersecurity ,
Data Security ,
Department of Defense (DOD) ,
DFARS ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Government Agencies ,
NIST ,
Regulatory Requirements ,
Reporting Requirements
As discussed in a recent Cozen O’Connor Alert, Diversity, Equity and Inclusion (DEI) has been at the top of President Trump’s mind, so much so that he recently issued an executive order effectively ending the use of DEI in...more
2/12/2025
/ Affirmative Action ,
Anti-Discrimination Policies ,
Civil Rights Act ,
Compliance ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Employment Discrimination ,
Enforcement Actions ,
Executive Orders ,
False Claims Act (FCA) ,
Federal Contractors ,
Trump Administration
On January 21, 2025, Judge Ryan T. Holte of the U.S. Court of Federal Claims issued a decision finding now former-President Biden’s February 4, 2022, Executive Order 14063 (EO) and the resulting Federal Acquisition...more
1/28/2025
/ Antitrust Provisions ,
Bid Protests ,
Bid Solicitation ,
CICA ,
Competition ,
Construction Industry ,
Court of Federal Claims ,
Executive Orders ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Government Agencies ,
Labor Relations ,
Project Labor Agreements ,
Subcontractors ,
Unfair Competition ,
Unions
The first two days of the new Trump administration were marked by pronouncements that portend short-run uncertainty about the tariff environment.
Although President Trump’s past statements had led many people to expect he...more
1/24/2025
/ China ,
Donald Trump ,
Drug Trafficking ,
Enforcement Actions ,
Executive Orders ,
Immigration ,
Intellectual Property Protection ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
National Security ,
Section 301 ,
Tariffs ,
Trade Act of 1974 ,
Trade Agreements ,
Trade Deficit ,
Trade Policy ,
Trade Relations ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA)
On January 21, 2025, President Donald Trump, under the auspices of promoting civil rights and merit-based opportunity by ending “illegal” diversity equity and inclusion (DEI) programs, revokes Executive Order (EO) 11246, as...more
1/24/2025
/ Affirmative Action ,
Department of Labor (DOL) ,
Discrimination ,
Diversity and Inclusion Standards (D&I) ,
Donald Trump ,
Employment Discrimination ,
Employment Policies ,
Equal Employment Opportunity Commission (EEOC) ,
Executive Orders ,
Federal Contractors ,
OFCCP ,
Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA)
On January 8, 2025, the Federal Acquisition Regulatory (FAR) Council withdrew its Proposed Rule on Pay Equity and Transparency in Federal Contracting (the proposed rule), which was initially introduced in January 2024. This...more
1/17/2025
/ Biden Administration ,
Department of Labor (DOL) ,
Employee Rights ,
Employment Discrimination ,
Employment Policies ,
Equal Employment Opportunity Commission (EEOC) ,
Equal Pay ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Pay Transparency ,
Proposed Rules ,
Reporting Requirements ,
State Labor Laws
On June 7, 2024, the U.S. Court of Appeals for the Federal Circuit broadened the Court of Federal Claims’ ability to oversee bid protests in Percipient.ai, Inc. v. United States. This case arose out of a bid protest to an...more
On Monday, June 24, 2024, a federal judge for the US District Court for the Northern District of Texas (the Court) instituted a nationwide injunction on the enforcement of portions of the US Department of Labor’s (DOL) 2023...more
7/2/2024
/ Armed Services Board of Contract Appeals ,
Construction Industry ,
Davis-Bacon Act ,
Department of Labor (DOL) ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Injunctions ,
Prime Contractor ,
Related Acts Clauses ,
Subcontractors ,
Wage and Hour
On April 1, 2024, the Department of Defense (DoD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA) issued a Final Rule amending the Federal Acquisition Regulation (FAR) to...more