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What a Relief: GAO’s FY 2021 Bid Protest Statistics Indicate That Nearly 50 Percent of Protests Are Effective

On November 16, 2021, the Government Accountability Office (“GAO”) issued its Bid Protest Annual Report for Fiscal Year 2021 (“FY 2021 Bid Protest Report”). The GAO’s annual Bid Protest Report to Congress—required under the...more

This Will Only Hurt a Bit: The GSA Mandates COVID-19 Vaccines in Nearly All Existing Contract Types

The General Services Administration (GSA) released its Class Deviation CD-2021-13 (the GSA Deviation), which, effective immediately, “provides instructions for the GSA acquisition workforce on when to include a new clause...more

The GAO Sustains Protest Based On Awardee’s Organizational Conflicts Of Interest—An Important Lesson For All Contractors

If a company has one or more Organizational Conflicts of Interest (“OCIs”), its ability to compete for (or perform) a government contract in a fair and equitable manner is inherently called into question. In the context of a...more

Summer In Bruges: The Procurement Collusion Strike Force Turns Its Eye Overseas

While most of us have been returning to some normality this summer by heading back to favorite vacation spots, the Procurement Collusion Strike Force (“PCSF”)—an arm of the United States Department of Justice’s Antitrust...more

DoD Issues Proposed Rule On Enhanced Post-Award Debriefing Rights

As you may recall, Section 818 of the National Defense Authorization Act for Fiscal Year 2018 (FY 2018 NDAA required the US Department of Defense (DoD) to draft regulations to establish comprehensive post-award debriefing...more

Recent GAO Decision Demonstrates The Utility Of Pre-Award Protests

In a time of uncertain federal budgets and an increasingly crowded marketplace, contractors of all sizes are on the lookout for ways to enhance their chances of winning federal business opportunities. Step one in this process...more

DOD Issues Final Rule Codifying The NISPOM

On December 21, 2020, the Department of Defense (DoD) Office of the Undersecretary of Defense for Intelligence & Security published a Final Rule codifying the National Industrial Security Program Operating Manual...more

The Beginning Of The Biden Administration – What Federal Contractors Need To Know

A new administration has moved into the White House, and, as anticipated, President Biden wasted no time in issuing, in the first few days of his presidency, a raft of Executive Orders (EOs) that appear calculated to set the...more

Excellent News For Protesters: GAO’s FY 2020 Bid Protest Report Reveals Record High Effectiveness Rate

On December 23, 2020, the Government Accountability Office (“GAO”) issued its annual Bid Protest Statistics for Fiscal Year 2020. As we’ve previously noted in this blog, the GAO’s yearly Bid Protest Report to Congress...more

Clarity, Sweet Clarity—Proposed Rule Will Revise The FAR Definition Of “Commercial Item”

On October 15, the FAR Council issued a Proposed Rule implementing amendments to the current FAR definition of “commercial item.” As explained below, the Proposed Rule will eliminate the current FAR definition of “commercial...more

The FAR Council’s Second Interim Rule Implementing NDAA Section 889(a)(1)(B): And The Hits Keep Coming!

Like the hits produced by DJ Khaled, the FAR Council offers “another one.” As covered extensively in this blog, federal contractors have been—or should have been (you have been working toward compliance, haven’t...more

DoD And GSA Release Guidance On Implementation Of Section 889 Part B

As covered recently in this blog, the Department of Defense (DoD), the General Services Administration (GSA), and the National Aeronautics and Space Administration released on July 14, 2020, an Interim Rule covering...more

Dear Magic 8-Ball—Should I Protest? Critical Protest Implications Following The Federal Circuit’s Expansion Of Blue & Gold’s...

Relying upon the cryptic answers provided by a Magic 8-Ball when deciding to file a protest at the United States Court of Federal Claims (COFC) may sound farcical, but a recent decision by a split panel of the United States...more

Risks, Reefs, and Wrecks: Charting A Course Through The Perils Of Covered Telecommunications Equipment And Services

Like the sailors of old, the government contracting community ventures forth knowing full well that danger lies ahead – although fortunately not in the form of a kraken, leviathan, or other mythical sea monster. Rather,...more

Alphabet Soup You Can Use: GSA Extends TAA & BAA PPE Waiver For COVID-19

Hold on to your alphabet . . . GSA extends the MAS CD&F waiver of TAA & BAA for COVID-19 PPE to 8/1/20. If that made sense to you, please proceed to the final paragraph. But for the acronymically challenged, when everything...more

Gambling On Compliance? DOJ Updates The House Rules On Corporate Compliance Program Expectations

When entering a casino, professional gamblers understand that “the house doesn’t beat the player. It just gives him the opportunity to beat himself.” This axiom is precisely why in the long run casinos make money, while...more

DoD Issues Draft Guidance For Contractor Reimbursement Under Section 3610 Of The CARES Act

Recently, the Defense Pricing and Contracting (“DPC”) unit under the Secretary of Defense issued draft implementation guidance for Department of Defense (“DoD”) contracting officers tasked with assessing contractor requests...more

The Evolution Of Contract Financing: Resurrecting Performance-Based Payments Under Fixed-Price Contracts

Contracting with the Department of Defense (DoD) can provide healthy opportunities for businesses of all sizes. That said, it is no secret that contractors without the cash resources to finance their performance while...more

No, No, THANK YOU. … GSA’s Class Deviation Provides Contractors With Welcome Guidance On The Implementation Of CARES Act Section...

To provide guidance on agency implementation of Section 3610 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), the General Services Administration (GSA) issued its April 21, 2020 Class Deviation...more

FEMA Opens A Door And Closes A Window: A Primer On FEMA’s Broad Efforts To Obtain And Retain Medical Supplies To Combat COVID-19

FEMA Seeks All Comers to Supply Government with COVID-19 Supplies Through its website, the Federal Emergency Management Association (“FEMA”) is encouraging the private sector to step up and support the agency in its...more

Commerciality In The Time Of Coronavirus—DCMA Issues New Class Commercial Item Determination And Guidance

On March 31, 2020, the Office of the Under Secretary of Defense for Acquisition and Sustainment issued a memorandum attaching a class Commercial Item Determination (CID) promulgated by the Defense Contract Management Agency...more

Massachusetts Order Requires All Non-essential Businesses To Close Workplaces

On Monday, March 23, Massachusetts Governor Charlie Baker issued a State of Emergency Order for Massachusetts (Order). The Order clarifies what businesses are deemed essential and non-essential (discussed in Exhibit A,...more

Delaware Modifies Declaration To Specify “Essential” And Non-Essential” Businesses And Mandates Citizens Stay-At-Home

On Sunday, March 22, Delaware Governor John Carney issued modifications four and five to the Declaration of a State of Emergency for Delaware (Declaration). The Fourth Modification clarifies what businesses are deemed...more

The Year In Protests: GAO Releases Its FY 2019 Bid Protest Statistics

Earlier this month, the Government Accountability Office (“GAO”) issued its annual Bid Protest Report to Congress for Fiscal Year 2019. Mandated by the Competition in Contracting Act, the GAO’s yearly Bid Protest Report...more

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