FAR Part 27 Overhaul: Key Changes to Intellectual Property in Federal Contracting
As part of the broader Revolutionary FAR Overhaul (RFO), Federal Acquisition Regulation (FAR) Part 27, which addresses patents, data, and copyrights was revised. While most changes were driven by the need for plain language, greater clarity, improved readability, and streamlined procedures, a few notable changes were introduced that will impact the treatment of intellectual property in federal government contracting. Special and Existing Works FAR Sections 27.405-1 and 27.405-2, which address special works and existing works, were revised. Notably, the prescriptions . . . Read More
Warfighting at Warp Speed: Why Defense Contractors Must Track the Department of War’s Acquisition Overhaul
The Secretary of War Pete Hegseth announced on November 7, 2025, that the U.S. Department of War (DOW) is dropping a game-changing memo: “ Transforming the Warfighting Acquisition System to Accelerate Fielding of Capabilities .” This bold blueprint reimagines how defense capabilities are delivered—with speed, agility, and results at the forefront. But with rapid transformation comes turbulence. While the newly branded Warfighting Acquisition System promises thrilling opportunities, it also introduces uncertainty. Defense contractors should stay sharp and informed. Understanding how DOW plans to fast-track contract delivery will be key to . . . Read More
Multijurisdictional Employers: Key Changes to Pay Transparency Laws in Massachusetts and California
Thirteen states, and additional city jurisdictions, have enacted pay transparency requirements. Many are far reaching and include job posting requirements for jobs that are remote or could be performed in the state. Massachusetts and California are the most recent states to mandate pay transparency actions or make changes to the requirements already in place. Employers with employees in Massachusetts and California should evaluate their hiring and pay transparency practices to avoid costly penalties. Also, visit this link to view replays of . . . Read More
Update on the DBE Interim Final Rule: DOT Issues Key Guidance for DBE Program Stakeholders
As PilieroMazza previously reported , via an interim final rule (IFR) effective October 3, 2025, the U.S. Department of Transportation (DOT) removed the use of race- and sex-based presumptions of social and economic disadvantage for establishing eligibility for its Disadvantaged Business Enterprise (DBE) and Airport Concessions DBE (ACDBE) Programs. [1] Given the lack of clarity with various aspects of the IFR, there is significant confusion among DBE Program stakeholders in terms of how the IFR is to be carried out. On October . . . Read More
Unfair by Design? Flaws in CPARS Disputes and What Needs to Change
The Contractor Performance Assessment Reporting System (CPARS) heavily influences who wins federal contracts, but its dispute process is anything but fair. Agencies can post their version of events—accurate or not—with little neutral oversight, while contractors get limited time to respond and few options for real correction. It’s time for reform. Independent reviews, temporary holds on disputed ratings, clear evidence rules, and enforceable deadlines would make CPARS more accurate and balanced. Lawmakers and industry leaders must act to make the CPARS . . . Read More
FASCSA Enforcement Begins: Acronis Order and What It Means for Federal Contractors
As PilieroMazza blogged about here , Federal Acquisition Supply Chain Security Act (FASCSA) Orders prohibit agencies from procuring or obtaining—or extending or renewing a contract to procure or obtain—any covered article, or any good or service produced or provided by a source. [1] The first FASCSA Order (Order) published on SAM.gov was released in September 2025 by the Office of the Director of National Intelligence (ODNI) excluding Acronis AG (Acronis), a Swiss-based cybersecurity company, from all Intelligence Community (IC) executive agency procurement actions as well . . . Read More
Why Business Leaders Should Speak Out During the Shutdown
On October 1, 2025, Congress failed to pass an appropriations bill to keep the federal government open. Three weeks have passed, and there is still no clear path forward. With each passing day, Republicans and Democrats alike become further entrenched in their positions, convinced that their cause is just. As a result, hardworking Americans, their families, and their businesses suffer. Government representatives who contend that holding out for an uncompromising win will be beneficial in the long run fail to . . . Read More
Contracting Through the Long Haul: Maximizing Recovery During a Protracted Government Shutdown
As the federal government shutdown continues, contractors are left to grapple with growing uncertainty regarding whether certain costs are recoverable or whether certain work can be performed. Previous client alerts emphasized that maintaining open and consistent lines of communication with your contracting officers (CO) is critical. Although some COs may be furloughed and unavailable, it is imperative to establish a record of your decisions, and why you believe those decisions to be reasonable under the circumstances. This client alert: (1) . . . Read More
FAR Part 19 Overhaul: What It Means for the 8(a) Program
On September 26, 2025, the Federal Acquisition Regulatory (FAR) Council released the FAR Part 19 model deviation text, significantly reorganizing the Part’s overall structure. The updated FAR Part 19 not only streamlines the layout to align with the acquisition lifecycle but also revises key rules governing set-aside contracts awarded under various small business programs. One of the most notable areas affected is the 8(a) Business Development Program. This blog provides a more detailed analysis of recent changes to the FAR . . . Read More
Long-Awaited Release of FAR Part 19: New Rule of Two and More
On September 26, 2025, the Federal Acquisition Regulatory Council released the much-anticipated rewrite of Federal Acquisition Regulation (FAR) Part 19, formerly titled Small Business Programs, as part of the broader Revolutionary FAR Overhaul initiative. To the pleasant surprise of many in the government contracting community, much of Part 19’s original content remains intact considering other more significant changes to other parts of the FAR. Still, several notable revisions—most prominently, retention of the Rule of Two—carry significant implications for small business . . . Read More