GAO Puts Disability Compliance Back in the Spotlight: What Federal Contractors Should Do Now
A recent Government Accountability Office (GAO) report, Disability Employment: DOL Should Enhance Monitoring and Guidance for Federal Contractors (GAO-26-107937), provides an important look at the current state of Section 503 enforcement and offers valuable clues about where the U.S. Department of Labor (DOL) may focus its efforts in the future. According to GAO, DOL has significantly reduced its oversight of federal contractor compliance with Section 503 of the Rehabilitation Act since early 2025, including suspending compliance audits that historically served . . . Read More
Primes, Subcontractors, and Litigation Beyond the CDA | Contract Claims 101, Part 8
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 . . . Read More
Required FOCI Submissions | The Shifting Landscape for Foreign Ownership, Control, or Influence, Part 3
Part 1 and Part 2 of this series explained how the Department of Defense’s Proposed Rule would expand Foreign Ownership, Control, or Influence (FOCI) obligations and how the current facility and personnel clearance framework operates. As the government sharpens its focus on foreign influence in the supply chain, the documentation cleared contractors must submit is increasingly consequential. In this installment, PilieroMazza attorneys turn to the paperwork that accompanies contractors’ FOCI and security clearance-related obligations, including the Standard Form 328 (SF . . . Read More
Final Rule, U.S. Companies and U.S. Persons Remain Exempt; Additional Exemptions | Corporate Transparency Act, Part 11
On August 14, 2026, FinCEN announced issuance of a final rule (Rule), that adopts all the changes from the interim final rule discussed in Part 10. The Rule continues to exempt both U.S. companies and U.S. persons under the Corporate Transparency Act (CTA) from reporting beneficial ownership information to FinCEN. The Rule also expands the exemptions to include reporting exemptions for “company applicants” that are U.S. persons and for U.S. persons who previously obtained a FinCEN identifier (FinCEN ID). Therefore, . . . Read More
DOT Finalizes DBE Program Revisions: Key Clarifications for Current and Prospective DBE Firms
On September 25, 2026, the U.S. Department of Transportation (DOT) will publish a final rule largely adopting its October 2025 interim final rule (IFR) that eliminated the race- and sex-based presumptions of social and economic disadvantage in the Disadvantaged Business Enterprise (DBE) and Airport Concession DBE (ACDBE) Programs. While DOT declined to make significant substantive changes to the IFR’s overall framework, the final rule provides several important clarifications and procedural revisions in response to the 637 comments received during the . . . Read More
Major Changes to Federal Contractors’ Compliance Requirements Coming this Monday, September 21
Effective September 21, 2026, a final rule adopted by the United States Department of Labor (DOL)’s Office of Federal Contract Compliance Programs (OFCCP) will eliminate several compliance requirements under Section 503 of the Rehabilitation Act (Section 503). This follows a pattern of recent final rules issued by the OFCCP signaling the dismantling of protections afforded to minorities, women, and now, individuals with disabilities. Here are what federal contractors should note come Monday, September 21. Self-Identification for Individuals with Disabilities Is . . . Read More
GovCon M&A and Organizational Conflicts of Interest: How Acquisitions Can Restrict Future Opportunities | The GovCon M&A Playbook, Part 6
A buyer identifies a government contractor with strong customer relationships, complementary capabilities, and a $100 million pipeline. The buyer expects the acquisition to open new markets, create cross-selling opportunities, and support growth across the combined company. Then diligence uncovers a problem. The buyer already performs program management, systems engineering and technical assistance (SETA), testing and evaluation, acquisition support, or other advisory work for some of the same agencies and programs. Its personnel may help develop requirements, evaluate contractor performance, advise . . . Read More
Warfighting at Warp Speed, Part 5: Software Acquisitions at Speed and Scale
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.” Now, the Department of the Army (Army), via Army Directive 2026-19, Enabling Modern Software Acquisition Practices (the Directive), has taken a concrete step to implement the DOW’s policy of focusing on acquiring and delivering weapons and business systems at speed and scale. Under the July 22, 2026 Directive, Army Secretary Driscoll announced the . . . Read More
GovCon M&A and Security Clearances: What Buyers Need to Know When Acquiring a Cleared Contractor | The GovCon M&A Playbook, Part 5
A private equity firm identifies an attractive government contractor. The company has strong margins, a healthy backlog, an experienced management team, and a significant amount of classified work. The buyer has reviewed the contracts, financials, employees, and customer relationships. The numbers work, and the deal model assumes the buyer can bring the company onto its broader platform after closing. Then someone asks what happens to the company’s facility security clearance when the deal closes. If the buyer has foreign ownership . . . Read More
GovCon M&A and Past Performance: Can Buyers Use a Target’s Experience After an Acquisition? | The GovCon M&A Playbook, Part 4
One of the most persistent misconceptions in GovCon M&A is that acquiring a contractor also means acquiring its past performance. Government contractors, investors, and acquirers frequently ask the same questions. Can the buyer use the target’s past performance? Does novation transfer past performance? Can the buyer rely on the target’s corporate experience in future proposals? The answer is sometimes, but not automatically. An acquisition does not turn the target’s past performance into the buyer’s own experience for every future competition. . . . Read More