News & Analysis as of

Rule of Two

Schwabe, Williamson & Wyatt PC

Potential Impacts of Trump’s DEI Executive Order on SBAs, Alaska Native Corporations, ‎and Tribes

On January 20, President Donald Trump issued an executive order titled “Ending Radical and Wasteful Government DEI Programs and Preferencing.” The order states that it ends “all discriminatory and illegal preferences,...more

Schwabe, Williamson & Wyatt PC

SBA’s Rule-of-Two Proposal Targets Increased Small-Business Set-Asides

On October 25, the Small Business Administration proposed a rule intended to increase small business participation in multiple-award contracts. The rule would apply the “Rule of Two” to task and delivery orders issued under...more

Maynard Nexsen

SBA Issues Proposed Rule to Require "Rule of Two" for Orders Under Multiple Award Contracts

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Today, the Small Business Administration issued a proposed rule that would expand the application of the "rule of two" (for small business) to orders under multiple award contracts. The proposed rule is welcome news for small...more

Sheppard Mullin Richter & Hampton LLP

What Are the 2022 Small Business Set-Aside Thresholds?

As we head into the new year, it seems like a good time to check-in on the adjusted small business set-aside thresholds for 2022. As you may recall, the threshold are tied both to the micro-purchase threshold and the...more

Bass, Berry & Sims PLC

COFC: “Rule of Two” Must Be Analyzed Before “Any” Acquisition

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The Court of Federal Claims (COFC) recently affirmed that agencies are required to apply the “Rule of Two” to all federal acquisitions in its decision of Tolliver Grp., Inc. v. United States. Further, agencies must give a...more

Morrison & Foerster LLP - Federal Circuitry

Last Week in the Federal Circuit: Waiver and Constitutional Avoidance

The Federal Circuit issued just one precedential opinion last week.  But it’s an interesting one:  The Court exercised its discretion to reach (or rather, avoid) a constitutional issue not pressed or passed upon by the trial...more

Holland & Knight LLP

February 2020 Small Business Roundup

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Veteran-Owned Business Priority - In 2016, the U.S. Supreme Court surprised many by hearing a bid protest concerning the application of the "Rule of Two" for veteran-owned small businesses in procurements run by the U.S....more

Bradley Arant Boult Cummings LLP

Protest Sustained: VA Based “Rule of Two” Determination on Canceled Set-Aside Solicitation

The Government Accountability Office (GAO) recently sustained a protest that challenged the Department of Veterans Affairs’ (VA) failure to set aside an acquisition for Service-Disabled Veteran-Owned Small Businesses (SDVOSB)...more

Holland & Knight LLP

GAO Rules That Kingdomware "Rule of Two" Does Not Govern Leasehold Acquisitions Conducted by GSA on Behalf of VA

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The U.S. Government Accountability Office (GAO) ruled on Dec. 20, 2019, that the "Rule of Two" of the Veterans Benefits, Health Care, and Information Technology Act of 2006 (VBA) does not require the U.S. General Services...more

Pillsbury Winthrop Shaw Pittman LLP

Government Fails Again to Apply the VA Rule of Two

GAO has decided that the Rule of Two is mandatory and universal, and that it applies even when the VA seeks to acquire goods and services through other government agencies. Another attempt by the VA to limit the...more

Sheppard Mullin Richter & Hampton LLP

Veterans Are First at the VA Following New Class Deviation Implementing Recent Federal Circuit Mandate

In its most recent attempt to strike the appropriate balance between the Veterans First and AbilityOne programs, the U.S. Department of Veterans Affairs (“VA”) issued on May 20, 2019 a class deviation to the VA Acquisition...more

Bradley Arant Boult Cummings LLP

The 3 Most Important Bid Protest Decisions Of 2018 - Law360

In 2018, three particularly important decisions were issued that will have a significant impact on bid protest law for years to come: Dell Federal Systems LP v. United States, PDS Consultants Inc. v. United States, and Oracle...more

Sheppard Mullin Richter & Hampton LLP

Federal Circuit Affirms Veteran-Owned Small Businesses Are the VA’s First Priority

The U.S. Court of Appeals for the Federal Circuit recently affirmed a May 2017 Court of Federal Claims decision requiring the U.S. Department of Veterans Affairs (“VA”) to give veteran-owned small businesses first priority...more

Pillsbury Winthrop Shaw Pittman LLP

Kingdomware Revisited: VA’s “Rule of Two” Takes Priority Over AbilityOne

The U.S. Court of Appeals for the Federal Circuit finds the Department of Veterans Affairs’ (VA) Rule of Two takes priority over older and less specific statutory procurement mandates. The Federal Circuit found that the VA...more

Jones Day

Court Puts Vets First: "Rule of Two" Prevails Over AbilityOne

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The U.S. Court of Federal Claims ("COFC") recently ruled that the Department of Veterans Affairs ("VA") must apply the "Rule of Two" before consulting the AbilityOne list when buying goods and services....more

PilieroMazza PLLC

House Proposes Broader Application of “VA Rule of Two” to Close Kingdomware Loophole

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On June 6, 2017, a bipartisan pair of lawmakers introduced a bill in the U.S. House of Representatives, H.R. 2781, known as the Ensuring Veteran Enterprise Participation in Strategic Sourcing Act (“Bill”), which, if passed,...more

PilieroMazza PLLC

Weekly Update Newsletter - December 2016 #4

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GOVERNMENT CONTRACTS - Payment of Subcontractors - The Department of Defense (“DOD”), General Services Administration (“GSA”), and National Aeronautics and Space Administration (‘NASA”), have issued a final rule...more

Smith Anderson

Supreme Court Requires Many More VOSB Set-Asides

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On June 16, 2016, the United States Supreme Court ruled that the Department of Veterans Affairs (VA) must apply the “Rule of Two” in all contracting decisions in Kingdomware Technologies, Inc. v. United States, 136 S.Ct. 1969...more

PilieroMazza PLLC

PilieroMazza Legal Advisor - Third Quarter

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GOVERNMENT CONTRACTING - Category Management: What Contractors Need to Know - In December 2014, the Office of Management and Budget (OMB) announced a new initiative called Category Management. This policy could...more

Bradley Arant Boult Cummings LLP

The “Rule of Two” Rules the Day in Supreme Court’s Decision Against the VA

The recently decided case of Kingdomware Technologies, Inc. v. United States marks a big win for small business-owning veterans. The Supreme Court unanimously decided that the Department of Veterans Affairs (VA)...more

Harris Beach Murtha PLLC

Construction Law Group News: Veteran-Owned Contractors: SCOTUS Reaffirms the “Rule of Two,” which is Good for You!

The U.S. Supreme Court’s ruling last week in Kingdomware Techs., Inc. v. U.S. should create more opportunities for veteran-owned and service-disabled veteran-owned small businesses (collectively, "VOSBs") to win contracts...more

Kilpatrick

Supreme Court Finds The Department of Veterans Affairs Violated Procurement Law – Are There Broader Implications for Government...

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On June 16, 2016 the Supreme Court of the United States (“SCOTUS”) issued its much anticipated decision in the Kingdomware Technologies, Inc. v. United States case (“Kingdomware”). One of two important cases, both decided on...more

Morgan Lewis

Supreme Court Requires the VA to Expand Use of Mandatory Set-Asides for VOSBs

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The Department of Veterans Affairs will be required to implement mandatory set-aside requirements for procurements at all levels, including FSS orders, if two or more VOSBs reasonably can be expected to submit offers that...more

Dorsey & Whitney LLP

The Supreme Court - June 2016 #4

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The Supreme Court of the United States issued decisions in three cases on June 16, 2016: Universal Health Services, Inc. v. United States ex rel. Escobar, No. 15-7: Yarushka Rivera, a teenage beneficiary of...more

PilieroMazza PLLC

Kingdomware Oral Arguments—Remand to Lower Courts Is a Possibility

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“Yeah, it’s a contract,” conceded Department of Justice (“DOJ”) attorney Zachary Tripp during recent oral arguments in Kingdomware Technologies Inc. v. United States. According to Tom Saunders, attorney for Kingdomware, that...more

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