The Weekly Update recaps recent legislative and regulatory updates affecting
government contractors and commercial businesses.
If you have questions concerning this content, please email marketing@pilieromazza.com.
_____________________________________________
PilieroMazza Deepens Deal-Making Bench, Enhances Corporate/M&A Capabilities with New Partner Kristen Centre, PilieroMazza Announcement, Kristen Centre, Abigail “Abby” L. Baker
PilieroMazza is pleased to announce that Kristen Centre joined the Firm as a Partner in our expanding Business & Transactions Group, further strengthening the Firm’s nationwide reach. Read more here.
The Shutdown Lowdown for Bid Protests, PilieroMazza Client Alert, Jon Williams, Katherine B. Burrows, Eric Valle
As federal contractors begin to grapple with the first government shutdown in several years, many are wondering how the shutdown will impact bid protests. This client alert provides the lowdown for how the shutdown will impact new and existing bid protests. Read more here.
5 Actions Employers Should Address with Employees as the Government Shutdown Looms, PilieroMazza Client Alert, Nichole D. Atallah, Sarah L. Nash
At midnight September 30, the federal government will run out of funds and contractors will start receiving stop-work orders for all work deemed non-essential. At the time of publication, compromise in Congress looks unlikely, and a protracted shutdown likely. In order to minimize costly personnel missteps, federal government contractors should consider the action items listed below BEFORE the government shuts its doors. For more comprehensive information on considerations for government contractors during a shutdown, please read our client alert “September 2025: Reducing the Negative Impacts of a Government Shutdown for Federal Contractors.” Read more here.
Upcoming Labor & Employment Presentations
TRAINING: ABCs of the SCA: Critical Path Service Contract Act Training for Government Contractors, October 21-23, 2025, Nichole D. Atallah, Sarah L. Nash
TRAINING: Labor Rules & Regulations: Federal Market Compliance, October 22, 2025, Nichole D. Atallah
CONFERENCE: Unpacking and Seizing Opportunity in Changes to Labor and Employment, November 20, 2025, Nichole D. Atallah
Vote to End Government Shutdown Fails as Democrats Hold Firm on Health Care Demands, The Associated Press
The U.S. Senate adjourned for the day on Wednesday with no resolution on how to reopen the government. Blame was being cast on all sides on the first day of the shutdown. A vote to end the government shutdown failed earlier Wednesday, as Democrats in the Senate held firm to the party’s demands to fund health care subsidies that President Donald Trump and Republicans refuse to extend. Read more here.
Contractors Angle for Opportunities Under DHS Spending Surge, Federal News Network
Federal contractors are positioning themselves to take advantage of a flood of new funding at the Department of Homeland Security, though DHS’s spending plans remain in flux. Contractors are flooding DHS with pitches, but the department’s plans for spending billions from the One Big Beautiful Bill remain in the air. Read more here.
Department of War (DOW)
- Class Deviation: Prohibition on the Procurement of Covered Semiconductor Products and Services from Companies Providing Covered Semiconductor Products and Services to Huawei: On September 22, DOW issued a memorandum, effective immediately, requiring Contracting Officers not to enter or renew contracts for procurement of covered semiconductor products and services for the Department of Defense with any entity that knowingly provides covered semiconductor products and services for Huawei. Read more here.
- Press Release: DOW Announces New Cybersecurity Risk Management Construct (CSRMC): On September 24, DOW announced the implementation of the CSRMC, a framework to deliver real-time cyber defense at operational speed. This five-phase construct ensures a hardened, verifiable, continuously monitored, and actively defended environment to ensure that U.S. warfighters maintain technological superiority against rapidly evolving and emerging cyber threats. Read more here. The CSRMC Strategic Tenets are available here. The CSRMC is available here.
Semiannual Regulatory Agenda
- Office of Federal Procurement Policy, Office of Management and Budget; Department of Defense; GSA; and National Aeronautics and Space Administration: On September 22, the Semiannual Regulatory Agenda was released. The agenda provides summary descriptions of regulations being developed by the Civilian Agency Acquisition Council and the Defense Acquisition Regulations Council in compliance with Executive Order 12866 “Regulatory Planning and Review, as reaffirmed and amended in Executive Order 13563, “Improving Regulation and Regulatory Review,” and Executive Order 14192, Unleashing Prosperity Through Deregulation.” The notice is available here.
- Small Business Administration (SBA): On September 22, SBA’s Semiannual Regulatory Agenda was released. The agenda is a summary of current and projected rulemakings and completed actions of the SBA. This summary information is intended to enable the public to be more aware of, and effectively participate in, SBA’s regulatory activities. Accordingly, SBA invites the public to submit comments on any aspect of this Agenda. The notice is available here.
Space Force Launches ‘First-Of-Its-Kind’ Acquisition Training Course, Federal News Network
In an effort to strengthen its acquisition workforce, the Space Force has rolled out a “first-of-its-kind” 10-week, in-residence course tailored for space acquisition. “Our military and civilian acquisition professionals are the center of gravity for delivering combat space capability,” Gen. Chance Saltzman said. Read more here.
Has Space Force Cracked the Code on Faster Acquisition? Government Executive
As the U.S. military waits for major acquisition reform legislation, Space Force officials say their service is ahead of the curve. Leaders say the service is “disrupting” the Valley of Death, among other innovations. Read more here.
Upcoming Government Contract Presentations
PM WEBINAR: Managing the Financial Impact of Tariffs on Your Government Contract, October 7, 2025, Jacqueline K. Unger, Ryan Boonstra
SEMINAR: What the Future Holds for Federal Procurement, October 8, 2025, Isaias “Cy” Alba, IV
PM WEBINAR: Overcoming the Compliance Minefield of Cost-Reimbursement Contracts, Part 2: Mastering DCAA Audits in Cost-Plus-Fixed-Fee Contracts, October 14, 2025, Isaias “Cy” Alba, IV
PM WEBINAR: Avoiding Common Teaming and Subcontracting Pitfalls, October 16, 2025, Jon Williams
TRAINING: Legal Considerations: How Best to Structure Your Company as a Federal Contractor, October 21, 2025, Isaias “Cy” Alba, IV
TRAINING: Past Performance: How to Use Yours, Benefit from Others’, and Defend It from Attacks, October 28, 2025, Daniel Figuenick, III, Abigail “Abby” Finan
TRAINING: Limitations on Subcontracting: Key Updates and Tips for Compliance, November 4, 2025, Emily A. Reid, Abigail “Abby” Finan
TRAINING: Unlocking the Secrets of Debriefings, Government Evaluation of Proposals and Protests, November 6, 2025, Katherine B. Burrows, Eric Valle
PM WEBINAR: Maximizing Recovery: Tactics for Stop Work REAs and Termination Proposals, November 6, 2025, Legal Strategies & Capture Planning, November 7, 2025, Lauren Brier
PM WEBINAR: Overcoming the Compliance Minefield of Cost-Reimbursement Contracts, Part 3: Ready, Set, Comply! Build Indirect Rates That Stand Up to DCAA Scrutiny, November 12, 2025, Isaias “Cy” Alba, IV
CONFERENCE: Mission Critical: Compliance and Preparing Defense Manufacturers for SBA’s Latest Rules, November 17, 2025, Isaias “Cy” Alba, IV
FAR Council Releases Updated Small Biz Regulations, Law360
The Trump administration released an updated version of the Federal Acquisition Regulation Part 19, preserving the rule of two for contracts, while removing re-representation requirements for small businesses when responding to orders under multiple-award contracts. Read more here (subscription required).
Federal Acquisition Regulation (FAR) Model Deviation Text for FAR Parts 14, 37, 41, and 47
On September 25, the FAR Council released the model deviation text for FAR Parts 14, 37, 41, and 47. Informal feedback on each is due November 3, 2025.
- FAR Part 14, Sealed Bidding, was simplified to make the regulation significantly more accessible, clear, and efficient for acquisition teams. Themes of the update for this part include: structural reorganization, consolidation, and plain language revisions and modernization to represent current practices. The General Services Administration’s (GSA) memorandum and class deviation fully incorporating the same into all GSA procurements are available here and will be effective November 3, 2025.
- FAR Part 37, Service Contracting, was restructured to follow the Acquisition Lifecycle with sections now titled Pre-solicitation, Evaluation and Award, and Post Award. Key topics like Performance-Based Acquisition (PBA), personal services rules, and the prohibition on contracting for inherently governmental functions have been moved from broader sections or the end of the part to their own distinct subparts at the beginning of the regulation, emphasizing their policy importance. GSA memorandum and class deviation fully incorporating the same into all GSA procurements are available here and will be effective November 3, 2025.
- FAR Part 41, Acquisition of Utility Services, was updated with minor changes to streamline and improve clarity, including a new definition for “utility service.” GSA memorandum and class deviation fully incorporating the same into all GSA procurements are available here and will be effective November 3, 2025.
- FAR Part 47, Transportation, was updated to remove 33 clauses. Commercial transportation remains the preferred shipping method. GSA memorandum and class deviation fully incorporating the same into all GSA procurements are available here and will be effective November 3, 2025.
Shutdown Showdown: Impact on Federal Contract Disputes, PilieroMazza Blog, Lauren Brier, Josie Farinelli
What happens to your contract administration disputes—such as termination settlement proposals (TSPs), requests for equitable adjustment (REAs), claims, and appeals—pending before Contracting Officers (COs), the Boards of Contact Appeal (BCAs), and the Court of Federal Claims (COFC) when the federal government shuts down? This question is especially relevant to the present shutdown, given the amount of terminations federal contractors are dealing with due to the change in administration and shifting government priorities in 2025. This blog provides a quick rundown of how the shutdown will impact new and existing TSPs, REAs, claims, and appeals. Read more here.
Contracting Misstep Could be Costly: Court Clarifies Incorporation by Reference, PilieroMazza Blog, Lauren Brier, Adel Mansour
A recent court decision delivers a stark warning to government contractors: failing to clearly include all the terms and conditions from your offer into the final contract could end up costing you. As this issue becomes increasingly common in federal contracting, the decision serves as a wake-up call for anyone drafting or negotiating government contracts. Read more here.
FALSE CLAIMS ACT / MERGERS & ACQUISITIONS
Upcoming False Claims Act Presentations
PM WEBINAR: FCA Implications for M&A Transactions, November 5, 2025, Matthew E. Feinberg, Kristen Centre
GSA Launches Second Phase of FedRAMP 20x Backed by OMB, NextGov/FCW
Greg Barbaccia, the federal chief information officer, says that the Office of Management and Budget is backing the General Services Administration’s overhaul of FedRAMP, the government’s cloud security assessment and authorization program. This next step in overhauling the federal government’s cloud security authorization program will pilot authorizations at the Moderate security level. Read more here.
Semiannual Regulatory Agenda, GSA
On September 22, GSA’s Semiannual Regulatory Agenda was released. The agenda announces the proposed regulatory actions that GSA plans for the next 12 months and those that were completed since the fall 2024 edition. This agenda was developed under the guidelines of Executive Orders 12866, “Regulatory Planning and Review,” Executive Order 13563, Improving Regulation and Regulatory Review,” Executive Order 14219, “Ensuring Lawful Governance and Implementing the President’s `Department of Government Efficiency’ Deregulatory Initiative,” and Executive Order 14192, “Unleashing Prosperity Through Deregulation.” GSA’s purpose in publishing this agenda is to allow interested persons an opportunity to participate in the rulemaking process. GSA also invites interested persons to recommend existing significant regulations for review to determine whether they should be modified or rescinded. The notice is available here.
General Services Administration (GSA) News Release: Meta Collaborate to Accelerate AI Adoption Across the Government
On September 22, GSA announced a OneGov initiative with Meta that supports government-wide use of Llama, its open-source AI models, making them more accessible to all federal departments and agencies. The streamlined OneGov approach eliminates individual agency negotiations, saving time and reducing duplicated efforts across the federal government. The full notice is available here.
HUD Joining GSA Centralized Acquisition Services Pilot, Federal News Network
The Department of Housing and Urban Development (HUD) is the third agency to move its contracting for common goods and services to the GSA. HUD joined the Office of Personnel Management and the Small Business Administration in using GSA’s Office of Centralized Acquisition Services for buying things like IT services, office management or medical supplies under the category management initiative. Read more here.
###