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.
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DOW’s New Cost and Pricing Transparency Memo: Key Considerations for Defense Contractors and Suppliers
PilieroMazza Client Alert; Authors: Isaias “Cy” Alba, IV, Lauren Brier, Josie Farinelli, Kristine “Krissy” Crallé
On October 1st, the Department of War (DOW) issued a memorandum, “Implementation of Supplier Cost and Pricing Transparency” (the Memo), establishing policies and procedures to “secure cost visibility across DOW’s acquisition portfolio, when necessary.” Although transparency is one of the Memo’s key objectives, the guidance may have the opposite effect for government contractors because it leaves individual contracting officers (COs) to determine when such visibility is “necessary.” The Memo intends to implement the DOW’s August 18th “Supplier Cost and Pricing Transparency” and September 14th “Fostering One Strong Industrial Base” memoranda, discussed in our most recent installment of the Warfighting at Warp Speed series. Read more here.
DOW’s Plan to Reset Cost and Pricing Transparency and Chart a Path from CAS to GAAP | Warfighting at Warp Speed, Part 6
PilieroMazza Blog; Authors: Lauren Brier, Josie Farinelli, Kristine “Krissy” Crallé
PilieroMazza has been covering the Department of War’s (DOW) acquisition overhaul since Secretary Hegseth’s November 2025 memorandum: “Transforming the Warfighting Acquisition System to Accelerate Fielding of Capabilities.” The latest overhaul news relates to contractor cost and pricing. On August 18, 2026, DOW released a memorandum entitled “Supplier Cost and Pricing Transparency,” closely followed on September 14, 2026, by “Fostering One Strong Industrial Base.” Together, the memoranda outline a new cost and pricing framework that pairs commercial accounting and market-based acquisition with broader Government access to contractor and subcontractor data. Read more here.
DOD Class Deviation 2026-O0027, Rev. 1: Revolutionary Federal Acquisition Regulation (FAR) Overhaul Part 17, Defense FAR Supplement (DFARS) Part 217
Source: U.S. Department of War
On October 7, DOD issued a class deviation, effective immediately, revising its class deviation issued on December 18, 2025. The deviation implements section 814 of the National Defense Authorization Act for Fiscal Year 2026 (NDAA FY26) (Pub. L. 119-60, 10 U.S.C. 3374(a)), new undefinitized contract action (UCA) reporting procedures, and removes the requirement for submission of Consolidated UCA Management Plans. Read more here.
DOD Class Deviation 2026-O0006, Rev. 2: Prohibition Regarding Russian Fossil Fuel and Fossil Fuel Business Operations
Source: U.S. Department of War
On October 7, DOD issued a class deviation, effective immediately, revising its class deviation issued on March 5, 2024. The deviation implements section 804 of the NDAA FY 2024 (Pub. L. 118-31) and section 846 of the NDAA FY26. Section 804, and the amendments in section 846, prohibits contracting officers (COs) from entering into a contract for the procurement of products or services with any entity that is, or that knowingly has fossil fuel business operations with an entity that is majority owned, individually or collectively, by an authority of the government of the Russian Federation; or a fossil fuel company that has fossil fuel business operations in the Russian Federation (with exceptions). The deviation requires COs to use DFARS 252.225-7966, Prohibition Regarding Russian Fossil Fuel Business Operations—Representation, and DFARS 252.225-7967, Prohibition Regarding Russian Fossil Fuel Business Operations, in most solicitations and contracts (with exceptions). Read more here.
SBA News Release: SBA Adds Five New Surety Bond Partners for Small Businesses Competing for Contracts
Source: U.S. Small Business Administration
On October 5, SBA announced that five new surety companies were approved during fiscal year 2026 to participate in its Surety Bond Guarantee Program. The expanded network will increase access to surety bonds for small businesses in construction, manufacturing, and supply-chain industries. Surety bonds help small businesses compete for and win public and private contracts by providing the customer with a guarantee that the work will be completed. Read more here.
SBA News Release: SBA Awards Over $7 Million Create Nine New Regional Innovation Clusters
Source: U.S. Small Business Administration
On October 6, SBA announced it awarded more than $7 million in awards to establish nine new Regional Innovation Clusters supporting small businesses and startups in biotechnology, defense, advanced manufacturing, and transportation. The clusters will serve as regional hubs connecting entrepreneurs with resources and opportunities—including business acceleration programs, market research, customer discovery, and government and commercial contracting assistance—to help them access funding, pursue procurement opportunities, and strengthen domestic supply chains. Read more here.
Five SBA Mentor-Protégé Joint Venture Pitfalls That Can Cost You a Contract
Source: Federal News Network
Joint ventures (JV) created under the Small Business Administration’s Mentor-Protégé Program (MPP) provide outstanding benefits for protégés to gain access to their mentors’ experience, resources, technical capabilities and past performance, and also benefit mentors by allowing them to expand their capabilities by pursuing small business contract opportunities for which they often otherwise would be ineligible. These benefits, however, are conditioned on strict compliance with SBA’s regulations, including the requirements governing the form and content of JV agreements. Failure to comply with SBA’s requirements, including those set forth below, can jeopardize the JV’s eligibility and result in the loss of significant contracts. Parties creating JVs under the MPP must make sure to avoid the following common pitfalls. Read more here.
DOD News Release: Department of War Announces $350 Million in Quantum Computing Initiatives
Source: U.S. Department of War
On October 8, DOD announced it is accelerating its efforts to identify, develop, and prepare for quantum computing capabilities that will underpin future national security missions. In support of the President’s Executive Order 14413, which mandated American leadership in quantum, the Office of the Under Secretary of War for Research and Engineering announced new initiatives and programmatic updates totaling approximately $350 million to strengthen U.S. leadership in quantum computing capabilities that support national security. Read more here.
DOD News Release: Trump, Hegseth Announce New Maryland Shipyard
Source: U.S. Department of War
On October 6, DOD announced the development of a new shipyard, to be called “Arsenal-2,” during a ceremony at the future site in Sparrows Point, Maryland. The project will include a $6.6 billion investment from the Navy and Anduril Industries, which will build and operate the facility. Read more here.
TSA Considers Next Steps for Privatized Screening After Gold+
Source: Federal News Network
The Transportation Security Administration (TSA) has scrapped the Gold+ privatization concept, but TSA leaders are still exploring how to expand privatized airport screening. Meanwhile, industry is pushing for TSA to consider the ideas that came out of the Gold+ acquisition process as the agency explores an “evolution” of its existing Screening Partnership Program. Read more here.
Pentagon Seeks New Ways to Open Classified Programs to Industry
Source: Federal News Network
Classified defense programs could soon see an influx of small businesses and other nontraditional contractors as the Pentagon tries to overcome longstanding hurdles to a more diverse industrial base. The department wants to address a catch-22 that has plagued businesses for decades: Companies need a facility security clearance to work on classified programs, but they need to work on classified programs to get that clearance. If a wider range of contractors can participate in America’s most technologically advanced, critical military programs, officials argue, those projects could see more innovation and lower costs. Read more here.
Pentagon, SBA Sign Agreement Expanding Capital Access for Defense Industrial Base
Source: The Hill
The Pentagon and the Small Business Administration (SBA) signed a new agreement that will expand access to strategic capital for small businesses in the U.S. defense industrial base. The agreement is building on the Smaller War Plants Commission (SWPC), which was announced in late August, and will aid suppliers, innovators, and manufacturers in gaining access to more capital to strengthen domestic supply chains and expand production. Read more here.
GAO Report: Artificial Intelligence (AI): Actions and Opportunities to Implement Responsible Use in DOD
Source: U.S. Government Accountability Office
On October 14, GAO released a Q&A detailing how the Department of Defense (DOD) has taken steps to implement AI responsibly, including through department-wide collaboration. GAO again calls out DOD for not defining responsibilities for AI collaboration or addressing workforce needs that affect AI adoption. GAO is recommending that Congress consider directing DOD to implement prior GAO recommendations on its AI collaboration and workforce. GAO is also making two new recommendations that DOD develop and issue a charter for the Responsible AI Working Council and ensure it addresses workforce needs of the CDAO Responsible AI Division. Read more here.
Upcoming Presentations
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*
GSA Activity Feed Announcement: Advanced Notice for MAS Solicitation Refresh 34 and Upcoming Mass Modification
Source: U.S. General Services Administration
On October 5, GSA announced it is planning to issue GSA MAS Refresh #34 on November 6, 2026. Contractors must accept the modifications no later than 90 days after the modification has been issued. Changes include updates on SCP-FSS-001 Instructions, GSA Acquisition Regulation Overhaul Wave 4, FSS Domestic End Product Certification, covered nitrile gloves and specific updates to SINs 561210FAC and 54151HACS. GSA is hosting a webinar on Monday, October 26, 2026. Read more here and here.
SBA News Release: SBA OIG and PRAC Reinforce Whole-of-Government Approach to Fraud Prevention
Source: U.S. Small Business Administration, Office of Inspector General
On October 7, SBA announced expanded fraud prevention and payment verification. Treasury reported expanding access to Do Not Pay data and screening approximately $3.7 trillion in federal payments during fiscal year 2026. Read more here.
Congress Can Make Real Progress on Preventing Fraud in the Lame Duck
Source: The Hill
While only a lame duck session remains in the 119th Congress, the House of Representatives has sent several bills to the Senate intended to helping agencies prevent fraud in federal spending programs, a problem that the Government Accountability Office estimates costs the federal government between $233 billion and $521 billion annually. Each of these bills is awaiting action in the Senate. With broad bipartisan support in the House, Senate leaders have an opportunity to hotline the bills when lawmakers return. Read more here.
INTELLECTUAL PROPERTY & TECHNOLOGY RIGHTS
New Federal Contracting Proposals Could Change Who Controls Intellectual Property
Source: Federal News Network
The latest round of proposals under the Revolutionary FAR Overhaul would affect everything from intellectual-property rights to Buy American requirements and subcontracting rules. Together, they offer another look at how far acquisition leaders are willing to go in reshaping the federal procurement system. Read more here.
AUDITS & INVESTIGATIONS / CYBERSECURITY & DATA PRIVACY
Watchdog to Examine Summertime Hack of DHS Information Network, Other Incidents
Source: Government Executive
A forthcoming audit of a key Department of Homeland Security (DHS) information-sharing network will examine three known security incidents that occurred on agency networks, including an intrusion by outside hackers that Nextgov/FCW first reported this summer, according to two people with knowledge of the matter. The review concerns the Homeland Security Information Network, or HSIN, which allows government agencies, law enforcement and other approved partners to exchange sensitive but unclassified information. Its users rely on the platform to share threat reporting, coordinate security for major events and respond to emergencies. Read more here.
Cantwell Unveils New AI Framework
Source: The Hill
Sen. Maria Cantwell (D-Wash.), the top Democrat on the Senate Commerce, Science and Transportation Committee, unveiled a framework Wednesday for regulating artificial intelligence amid growing pressure on lawmakers to address the technology’s risks. Read more here.
CYBERSECURITY & DATA PRIVACY / WHITE COLLAR DEFENSE
DOJ Press Release: Known Cybersecurity Expert and Owner of Florida Ransomware Remediation Company Charged with Defrauding Clients
Source: U.S. Department of Justice
On October 7, DOJ announced that Zohar Pinhasi was arraigned in the Eastern District of New York on wire fraud charges relating to Pinhasi’s false representations that he could decrypt ransomware without paying cybercriminals. Pinhasi claimed to prospective clients that his company, MonsterCloud, offered a principled alternative to paying off ransomware attackers. Read more here.
DOL Notice: Minimum Wage for Federal Contracts Covered by Executive Order (EO) 13658, Notice of Rate Change in Effect for 2027
Source: Federal Register
On October 8, DOL’s Wage and Hour Division (WHD) published a notice, effective January 6, 2027, implementing EO 13658 increasing the minimum wage to $14.08 per hour and, for tipped employees, $9.85 per hour on covered contracts. Read more here.
California Takes Major Step to Regulate AI In the Workplace
Source: Route Fifty
The state recently passed the ‘No Robo Bosses’ Act, making it the first in the nation to restrict employers from relying on artificial intelligence for hiring or disciplinary actions. California Gov. Gavin Newsom signed a bill late last month that made the state the first in the nation to require human review for certain employment decisions made by automated systems. Read more here.
Labor Has Mostly Stopped Checking Whether Federal Contractors Are Following Disability Rules
Source: Government Executive
A watchdog found that the Office of Federal Contract Compliance Programs has no plans to restart routine audits, leaving less oversight of protections for workers with disabilities. As the Trump administration slashed a Labor Department agency’s workforce and jurisdiction, the office’s enforcement of certain anti-disability discrimination rules that are still on the books was nevertheless weakened by the overhauls. 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