The Department of Defense (DoD) is preparing to roll out new requirements that will significantly expand how it evaluates and mitigates foreign ownership, control, or influence (FOCI) across its contractor base. Under Section 847 of the Fiscal Year 2020 National Defense Authorization Act (NDAA), the DoD must establish procedures to assess and mitigate FOCI risks for both cleared and uncleared contractors involved in unclassified defense contracts, subcontracts, or research awards valued at $5 million or more. In May 2024, the DoD took its first formal step toward implementation by issuing DoD Instruction 5205.87, which sets policy for evaluating beneficial ownership and identifying potential foreign control early in the contracting process. Continue Reading Preparing for DoD’s Upcoming DFARS Rule on Beneficial Ownership and FOCI Vetting
COFC Decision Highlights Risks in Mentor-Protégé Joint Venture Agreements
On September 18, the Court of Federal Claims (COFC) issued a decision in Multimedia Environmental Compliance Group JV v. United States, denying a bid protest that challenged the Small Business Administration’s (SBA’s) Office of Hearings and Appeals (OHA) ruling on joint venture eligibility. Continue Reading COFC Decision Highlights Risks in Mentor-Protégé Joint Venture Agreements
FAR Part 19 Rewrite: Key Developments for Small Business Contracting
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
FAR Council’s Final Rule Requiring Active SAM Registration at Two-Points in the Contract Acquisition Process
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
Legal/Legislative Update at the GWSCPA 2025 Government Contracting Conference
On September 25, join me in Vienna, Virginia at the Greater Washington Society of CPAs (GWSCPA) 2025 Government Contracting Conference where I will lead a session on the latest Legislative and Legal Updates.Continue Reading Legal/Legislative Update at the GWSCPA 2025 Government Contracting Conference
SBA Proposes Bigger Size Standards: What It Means for Small Businesses
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
Robust Federal Contracts Market in Huntsville
I was quoted by the Huntsville Business Journal (HBJ) in a recent article about the metro area’s economy, which relies heavily on government contract work, and why it may be positioned for even more federal growth. Currently, the Huntsville area market relies on what I called its “three major pillars” of federal contract work stemming from NASA, Redstone Arsenal and the FBI.Continue Reading Robust Federal Contracts Market in Huntsville
OFPP Green Lights Immediate Use of Revised Procurement Rules
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
Manufacturing & Industrial: Outlook & Trends
Manufacturers are operating in a period of both opportunity and uncertainty. Buyer demand remains strong in a competitive M&A market, but shifting tariff policies, heightened immigration enforcement, and an evolving regulatory agenda are reshaping how companies plan for growth.
Continue Reading Manufacturing & Industrial: Outlook & Trends
FAR Final Rule Clarifies SAM Registration
On August 7, the Federal Acquisition Regulatory (FAR) Council issued a final rule, published in the Federal Register, 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. Continue Reading FAR Final Rule Clarifies SAM Registration