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.
_____________________________________________
Primes, Subcontractors, and Litigation Beyond the CDA | Contract Claims 101, Part 8
PilieroMazza Blog; Authors: Lauren Brier, Shelleah J. Cannon
In its “Contract Claims 101” series, PilieroMazza has discussed issues and considerations that may be familiar to most federal contractors, including requests for equitable adjustment (REAs), Contract Disputes Act (CDA) claims, contracting officer final decisions, and appeals to the Boards of Contract Appeals or the U.S. Court of Federal Claims. However,a dispute between a prime contractor and its subcontractor, or between a subcontractor and a lower-tier subcontractor, follows a completely different path. Typically, a dispute between the parties requires them to enforce or defend a private subcontract, not invoking the CDA. That distinction matters. Contractors that treat a subcontract dispute like a CDA claim—or wait for the government’s process to resolve a private payment or performance issue—can lose leverage and, in some cases, rights. Read more here.
GSA Memo to Set AI-Specific Acquisition Rules
Source: NextGov/FCW
The General Services Administration is adjusting its acquisition regulation to include language aimed at protecting government data that contractors process in large language models. The language includes changes some industry groups have requested through a public comment period and will go into effect Oct. 19. Read more here.
Pentagon Update on National Defense Strategy Cites Progress, Omits Key Threats
Source: Defense One
The Pentagon’s latest report about its implementation of the National Defense Strategy notes progress on accelerating weapons production, cutting red tape, and persuading European governments to boost defense spending—but is light on problems such as Russia’s increasing aggression in Europe and the high cost of U.S. wars in the Middle East. The report to Congress notes accomplishments but masks depleted arsenals, strategic distractions, and a quiet retreat from European defense. Read more here.
Department of Defense (DOD) Memorandum: Implementation of Supplier Cost and Pricing Transparency
Source: U.S. Department of Defense
On October 1, DOD issued a memorandum implementing other memoranda to reinforce policy and procedures to secure cost visibility across its acquisition portfolio, as necessary. Read more here.
In ‘Unusual Arrangement,’ Rhodes Continues to Drive FAR Overhaul
Source: Federal News Network
Kevin Rhodes may have stepped down as the administrator of the Office of Federal Procurement Policy in September, but that doesn’t mean he’s out of government. Federal News Network has confirmed that Rhodes is now a special government employee continuing to work on two key administration acquisition reform initiatives: the overhaul of the Federal Acquisition Regulation (FAR) and the update to the regulations that govern cost accounting standards. Read more here.
General Services Administration (GSA) Proposed Rule: GSA Acquisition Regulation (GSAR); GSAR Implementation of Executive Order 14275, Acquisition of Utility Services
Source: Federal Register
On October 5, GSA published a proposed rule in which it is proposing to amend the GSAR part 541 which outlines procedures and guidance for the procurement of utility services. The proposed rule would align the GSAR with the FAR Council’s proposed rule for FAR part 41. The proposed rule is available here. Comments are due November 4, 2026.
GSA Memo to Set AI-Specific Acquisition Rules
Source: Government Executive
GSA is adjusting its acquisition regulation to include language aimed at protecting government data that contractors process in large language models. Buried on page 129 of an agency memo signed by GSA Senior Procurement Executive Jeffrey Koses is a section titled “Basic Safeguarding of Data within Large Language Model Artificial Intelligence Systems.” The section details what data protections contractors and subcontractors must include when their LLMs process government data. Read more here.
Small Business Administration (SBA) News Release: SBA Awards $3.75 Million to Train Veteran-Owned Small Businesses to Compete for Federal Contracts
Source: U.S. Small Business Administration
On October 2, SBA announced it awarded a $3.75 million grant over five years to the Maryland-based Montgomery County Chamber of Commerce Community Foundation Veterans Institute for Procurement. The organization will operate the Veteran Federal Procurement Entrepreneurship Training Program, a nationwide initiative to help veteran-owned small businesses build the knowledge, capabilities, and procurement readiness to compete for federal contracts. Read more here.
SBA News Release: SBA Awards $5.3 Million to Expand National Women’s Business Center Network
Source: U.S. Small Business Administration
On October 2, SBA announced five grant recipients under its new Women’s Business Center (WBC) Modernization Initiative, awarding a combined $5.3 million to expand statewide support networks for women entrepreneurs in Florida, Pennsylvania, Tennessee, Texas, and West Virginia. The Initiative is designed to augment resources in states where existing WBC funding has not kept pace with the number of women entrepreneurs. Read more here.
Why Government Contracting Risk Strategy Needs to Keep Pace with the Changing Procurement
Landscape
Source: Federal News Network
Government contractors feel procurement pressure in their pipelines and profits. A stalled proposal consumes senior labor before revenue appears. Delayed subcontractor input can weaken pricing confidence and force teams to rebuild pursuit strategy. Compliance documentation that falls behind a faster acquisition timeline can pull experienced people from delivery into remediation. Over time, recurring pursuit, remediation and rework costs can erode margin, pressure cash flow and reduce capital for growth. Read more here.
DISA Once Again Seeks to Expand Leidos’ Enclave Contract
Source: Federal News Network
The Defense Information Systems Agency (DISA) is once again trying to add the combatant command network migration work to Leidos’ $11 billion Defense Enclave Services contract. In a justification document published on Monday, DISA said Leidos was the only company capable of transitioning all combatant commands to the Defense Department Network. Read more here.
WEBINARS:
Women in GovCon: Real Talk on Workforce Strategy, Compliance, and Growth
October 22, 2026
The Boon Group & GSA National
Speaker: Nichole D. Atallah
PM WEBINARS:
TRAINING: ABCs of the SCA: Critical Path Service Contract Act Training for Government Contractors
October 27-29, 2026
PilieroMazza Training Sessions
Speakers: Nichole D. Atallah, Sarah L. Nash, Georgianne “Georgi” Kokenis
CONFERENCES:
Protecting Your Competitive Position While Maintaining A Disciplined Legal Strategy
November 5, 2026
SAME 2026 Federal Small Business Conference
Speaker: Tracey L. Pruiett*
DHS Readies Major Cyber Contract
Source: Federal News Network
The Department of Homeland Security (DHS) is preparing this year to award a major cloud, cybersecurity and network services contract aimed at further centralizing the management of IT services across DHS. In a notice posted to Sam.gov last month, DHS laid out the notional timeline for award of the Network, Cloud and Cybersecurity Services 2.0 vehicle, known as NCCS 2.0. The notice included a draft request for proposals and a draft statement of work. Read more here.
CYBERSECURITY & DATA PRIVACY / LABOR & EMPLOYMENT
CISA to Keep Cyber Pay Incentives, But Less Staff Will Qualify
Source: Federal News Network
The Cybersecurity and Infrastructure Security Agency is continuing to offer cyber pay incentives to retain skilled technical staff, but fewer employees will qualify for the program under revised criteria that tie eligibility to job series and performance ratings. The revisions to the incentives program have sparked concern that CISA could lose more employees after widescale departures last year. Read more here.
Department of Labor (DOL) News Release: DOL Awards $43 Million to 7 States to Support Skills
Training In Shipbuilding, Manufacturing, Aerospace, Other Critical Industries
Source: U.S. Department of Labor
On September 30, DOL announced that the Employment and Training Administration issued the second round of awards of $43 million in Industry-Driven Skills Training Fund grants to seven states to invest in employer-driven skills training programs for critical industries like shipbuilding, advanced manufacturing, and nuclear energy. Read more here.
Government Accountability Office (GAO) Report: Disability Employment: DOL Should Enhance Monitoring and Guidance For Federal Contractors
Source: U.S. Government Accountability Office
On October 6, GAO released a report detailing its review of the implementation and oversight of Section 503. This report addresses (1) the extent to which DOL monitors Section 503 compliance and plans for its workforce needs, and (2) what challenges, if any, contractors face in complying with Section 503 and the extent to which DOL has provided resources to assist contractors. GAO recommended that DOL resume compliance audits, conduct strategic workforce planning for OFCCP, and provide additional information to help contractors provide reasonable accommodations to employees with disabilities and comply with Section 503. Read more here.
Appeals Court Seemingly Oks VA’s Contested Union Contract Expiration
Source: Government Executive
A federal appeals court has seemingly cleared the way for the Veterans Affairs Department to allow its contract with the American Federation of Government Employees to expire. A three-judge panel found that a judge’s ruling in August forcing the VA to maintain its CBAs with AFGE improperly delved into questions of compliance with particular contract provisions. Read more here.
CONFERENCES:
Federal Government Contracting 101: A Roadmap for Commercial Businesses
October 17, 2026
ACRA’s 32nd Annual Conference
Speaker: Timothy “Tim” F. Valley, Jr.
Upcoming Presentations
PM WEBINARS:
Buying and Selling a Business: M&A Processes and Procedures
October 21, 2026
Speaker: Kristen Centre