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Richard Arnholt

Richard Arnholt advises companies, large and small, on the complex rules and regulations applicable to grants and contracts from federal and state governmental entities. In an era of increased budgetary pressures for contractors, Richard focuses his practice on providing practical business and legal guidance to help clients efficiently navigate the minefield of government procurement and grant regulations.

The U.S. Small Business Administration (SBA) has suspended 1,091 participants in the 8(a) Business Development Program after concluding that those firms did not timely submit required documentation in response to SBA’s recent program-wide data request. The suspensions are part of a broader effort by SBA to audit the 8(a) program and root out fraud, waste, and abuse.Continue Reading SBA Suspends Over 1,000 8(a) Participants After Program-Wide Audit Data Request While DoW Announces Line-By-Line Review of All Small Business Awards Over $20 Million

The Federal Acquisition Regulatory (FAR) Council recently released its long-awaited overhaul of FAR Part 19, the section governing small business programs. While the rewrite is part of the Trump administration’s broader initiative to reduce the FAR to statutory and “essential” provisions, the changes to Part 19 carry significant implications for both small and large contractors.Continue Reading FAR Part 19 Rewrite: Key Developments for Small Business Contracting

I recently authored an article for Washington Technology discussing the recent final rule published by the Federal Acquisition Regulatory (FAR) Council clarifying that an offeror must be registered in the federal System for Award Management (SAM) when submitting an offer and when the contract is awarded, and how the rule change affects businesses trying to acquire federal contracts.Continue Reading FAR Council’s Final Rule Requiring Active SAM Registration at Two-Points in the Contract Acquisition Process

On August 22, the U.S. Small Business Administration (SBA) proposed an important change that could affect thousands of companies competing for federal contracts. In the proposed rule, the SBA suggested raising certain size standards used to determine when a company is considered “small.” If finalized in its current form, the proposal will increase thresholds across 263 industries, from telecommunications and natural gas pipelines to commercial banking, and could add more than 11,000 firms to the small business category.Continue Reading SBA Proposes Bigger Size Standards: What It Means for Small Businesses

The Department of Defense (DoD) has issued its long-awaited final rule implementing the Cybersecurity Maturity Model Certification (CMMC) program into the Defense Federal Acquisition Regulation Supplement (DFARS). The rule establishes a three-year phased rollout that will ultimately apply to nearly every contractor and subcontractor handling federal contract information (FCI) and controlled unclassified information (CUI) (the new requirements do not apply to awards that do not involve the handling or transmission of FCI or CUI). Continue Reading DoD Finalizes CMMC Rule: What Defense Contractors Need to Know

On August 15, the White House Office of Management and Budget’s (OMB) Office of Federal Procurement Policy (OFPP) announced agencies may “immediately begin eliminating one-third of requirements from their future contracts that are not required by statute or executive orders and have little to do with contract outcomes.” Continue Reading OFPP Green Lights Immediate Use of Revised Procurement Rules

The federal government’s commitment to supporting small businesses through procurement remains strong, but the shape and scale of that support may soon look very different. In accordance with recent executive orders, sweeping changes to acquisition policies are already underway and the future of key non-statutory provisions favoring small businesses is uncertain. While there has been no clear indication that the Federal Acquisition Regulation (FAR) Council intends to eliminate one of the most important of those provisions, known as “the Rule of Two,” its non‑statutory status means such a move is within the realm of possibility and is likely the reason that, as noted below, legislation codifying the Rule of Two was introduced earlier this year. This uncertainty underscores how dynamic the government contracting landscape has become and raises important questions about how reforms could impact small businesses that rely on federal contracts.Continue Reading Small Business Alert – Possible End for the Rule of Two?

As we noted in this blog post in February, the 2025 National Defense Authorization Act (NDAA) was enacted in December 2024 included a provision at Section 885 raising the protest threshold for Department of Defense (DoD), Coast Guard, and NASA task orders from $25 million to $35 million. Continue Reading GAO Proposes Higher Pleading Standard for Bid Protests, Questions Remain for Loser-Pays Model