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Commerce Department Considers Applying Section 232 Duties on Steel and Aluminum to More Construction Materials

Duties on steel and aluminum have already had a significant impact on the construction industry. Participants in the construction industry have a very short window in which to weigh in on changes that could increase the...more

DOJ Establishes Civil Rights Fraud Initiative Targeting Corporate DEI Programs and Antisemitism

On Monday, May 19, 2025, the U.S. Department of Justice (DOJ) announced a new initiative titled the Civil Rights Fraud Initiative, which will use the False Claims Act (FCA) to further the Trump Administration’s stated goals...more

Is this the End of the Small Business Set Aside Programs? DOT Issues New Guidance Letter

On April 24, 2025, the U.S. Department of Transportation (DOT) Secretary, Sean P. Duffy, issued a guidance letter to all grant recipients of DOT funding, notifying them of: 1. The DOT’s new interpretations of...more

And Here We Go – Reformation of the FAR Directed by Executive Order

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

An Executive Order that Makes Sense (sort of)

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

IF IT COMES – Are you ready for another possible government shutdown?

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

Tackling Potential Tariff Impacts on Awarded Federal Contracts & Private Construction Contracts

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

Enter DOGE: Trump Executive Order Formalizes DOGE and Directs Agencies on Next Cost Cutting Steps

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

AG Memorandum Instructs DOJ to Investigate and Eliminate Illegal DEI Initiatives in Light of EO 14173

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

U.S. Court of Federal Claims Finds Project Labor Agreements Violate the Competition in Contracts Act

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

FAR Council Withdraws Proposed Rule on Federal Contractor Pay Requests

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

Deadline for Federal Contractors to Object to New OFCCP FOIA Requests: December 10, 2024

The U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) published a notice in the Federal Register on October 29, 2024, notifying federal contractors of its receipt of two new requests under the...more

Department of Defense Publishes Final Rule on Cybersecurity Maturity Model Certification

On October 15, 2024, the Department of Defense (DoD) published the long-anticipated first part of its final rule (the Final Rule) for the Cybersecurity Maturity Model Certification (CMMC) program. After the implementation of...more

How the End of Chevron Deference Could Impact Government Contractors

On June 28, 2024, the Supreme Court of the United States (SCOTUS) issued its decision in Loper Bright Enterprises v. Raimondo, which put an end to Chevron Deference. Chevron Deference was a doctrine that required courts to...more

Federal Circuit Increases Jurisdictional Scope for Bid Protests in Percipient.ai, Inc. v. United States

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

Federal Judge Blocks Portions of Department of Labor Rulemaking on Davis-Bacon Act

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

Supreme Court Says “Stay” Means “Stay,” Not “Dismiss,” in Resolving FAA Circuit Split

On May 16, 2024, the Supreme Court, in Smith v. Spizzirri, unanimously held that Section 3 of the Federal Arbitration Act (FAA) requires courts to stay, rather than dismiss, proceedings pending arbitration upon a party’s...more

US DOT Updates its Rules Regarding the Disadvantaged Business Enterprise Program

On April 9, 2024, The U.S. Department of Transportation (DOT) announced numerous revisions to its in-place rules for administering its Disadvantaged Business Enterprise (DBE) Program. The new rule follows a Notice of Proposed...more

Trade in Your Hard Hat for a Safety Helmet: OSHA Looks to Set an Example on Job Site Headgear

The Occupational Safety and Health Administration (OSHA) issued a Trade Release on December 11, 2023, announcing that its employees will now wear safety helmets instead of hard hats on inspection sites. This follows a...more

Government Shutdown Imminent: Are You Ready?

September 30th represents a number of things, the end of September, entry into Autumn, and, most critically, the end of the Federal Government’s fiscal year, to name a few. As such, the Government must have a budget in place...more

Court Ruling Leads to Major Change in SBA 8(a) Social Disadvantage Determination Policy

Some significant (perhaps short-term) changes have rapidly come to the U.S. Small Business Administration’s (SBA) 8(a) Business Development Program (8(a) or the Program) following a U.S. Federal District Court for the...more

Build America, Buy America Final Guidance Issued

On August 14, the Office of Management and Budget (OMB) issued a “pre-publication” version of its final guidance to promote the use of American-made materials in federally funded infrastructure projects.1 The guidance...more

Changes Coming for Government Construction Contractors as DOL Revises Davis-Bacon Act Regulations

On August 8, 2023, the U.S. Department of Labor (DOL or the Department) issued a Final Rule titled “Updating the Davis-Bacon and Related Acts Regulation” (the Final Rule), comprising 812 pages. The changes made in this Final...more

It’s (Not) About Time - Government May Move to Dismiss FCA Suit at Any Point During its Pendency

On Friday, June 16, 2023, the United States Supreme Court (SCOTUS or the Court) upheld prior decisions by the trial court and Third Circuit in U.S. ex rel. Polansky v. Executive Health Resources, Inc. Polansky involves the...more

Unanimous Supreme Court Holds (Reaffirms) False Claims Act Responsibility Requires Offender’s Belief of Lie

On June 1, 2023, the United States Supreme Court issued its ruling in two consolidated cases concerning the False Claims Act (FCA), United States ex rel. Schutte et al. v. SuperValu Inc. et al., Case No. 21-1326, and United...more

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