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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Season’s Greetings from PilieroMazza!
GOVERNMENT CONTRACTS / FALSE CLAIMS ACT / AUDITS & INVESTIGATIONS
SBA’s 8(a) Program Audit Starts—PilieroMazza Launches “8(a) Audit Response Task Force” to Help Clients Handle the Holiday Gift No One Asked For, PilieroMazza Client Alert, Matthew E. Feinberg, Meghan F. Leemon
On December 5, 2025, the Small Business Administration (SBA) issued formal data and document requests (linked here) to certified 8(a) Business Development Program participants. This follows SBA’s June 2025 announcement that it would implement an “immediate and full-scale audit” of the 8(a) Program. The requests, issued by the SBA Office of General Counsel via email, justified the audit as follows: “Recent reports by journalists and independent investigators have raised questions about widespread misconduct within the 8(a) Businesses [sic] Development Program, adding to years of credible concerns that the program designed to serve ‘socially and economically disadvantaged’ businesses has become a vehicle for institutionalized abuse at taxpayer expense.” Given the wide-ranging scope of the full-program audit, PilieroMazza launched an “8(a) Audit Response Task Force” to assist clients in navigating SBA’s audit requests and any ongoing or future investigations, inquiries, and litigation arising out of the audit. Read more here.
Upcoming Presentations
PM WEBINAR: Inside the SBA’s Full-Scale 8(a) Audit: What Participants Need to Know Now, December 17, 2025, Matthew E. Feinberg, Meghan F. Leemon
Warfighting at Warp Speed: Tracking the 2026 NDAA and DOW’s Acquisition Overhaul, PilieroMazza Blog, Lauren Brier, Josie Farinelli
In November, PilieroMazza explained the Department of War’s (DOW) Acquisition Overhaul and why defense contractors need to stay informed, as understanding how DOW plans to fast-track contract delivery will be key to thriving in this evolving landscape. Since DOW released its plans in a memo titled “Transforming the Warfighting Acquisition System to Accelerate Fielding of Capabilities,” the government took further action to reshape the defense acquisition process via the 2026 National Defense Authorization Act (NDAA) released by Congress on December 7, 2025. In this blog, we break down key highlights from the 3,000-page NDAA for defense contractors tracking how these important updates will affect their ability to compete. Read more here.
Cy Alba Talks to Federal News Network on DOD’s Plan to Cap Profits for Value-Added Resellers, PilieroMazza News, Isaias “Cy” Alba, IV
In a draft memo, the Pentagon would place a 5% cap on most fees charged by value-added resellers (VARS), starting with a specific special item number (SIN) for IT products. This cap would only apply to IT products sold through the General Services Administration’s schedule contract. The draft memo is one of two expected from the administration to address what it believes are higher-than-normal costs when buying IT products and services through resellers. Read more here.
House Overwhelmingly Passes $900B Annual Defense Bill, The Hill
The House on Wednesday easily passed the annual defense policy bill, sending the mammoth, $900 billion measure to the Senate ahead of the year-end deadline. The Bill passed the lower chamber by a vote of 312-112. Ninety-four Democrats and 18 Republicans opposed the bill. Read more here.
FAR Companion Version 2.0 Feedback Requested
The FAR Council welcomes feedback for the FAR Companion, Version 2.0, on general input on the new non-regulatory resource, any annotations that warrant refinement or clarification, and any additional annotations for consideration. Feedback is due no later than January 15, 2026, at 4:30 pm ET. Feedback can be submitted here.
Department of War (DOW) News Release: The War Department Unleashes AI on New GenAI.mil Platform
On December 9, DOW announced the launch of Google Cloud’s Gemini for Government as the first of several frontier AI capabilities to be housed on GenAI.mil. This initiative cultivates an “AI-first” workforce, leveraging generative AI capabilities to create a more efficient and battle-ready enterprise. Additional AI models will be available to all civilians, contractors, and military personnel, delivering on the White House’s AI Action Plan announced earlier this year. Read more here.
Trump’s Government Management Vision Centers on Elimination, Accountability, Federal News Network
The Trump administration has laid out its President’s Management Agenda, providing a framework for the administration’s overarching priorities to drive change in the federal government for the next few years. The new PMA, which the Office of Management and Budget published on December 8, includes three key priority areas, each of which contains several underlying goals the administration wants to meet, such as eliminating “woke” government, ending “over-classification,” and “buying American.” Read more here.
American Retailers Oppose Funding Plan to Expand US Shipbuilding, Bloomberg Government
Groups representing iconic American companies are the top foes of bipartisan legislation to revive domestic shipbuilding to improve national security. Import-dependent retailers object to how the SHIPS for America Act (S. 1541) would increase their costs by slapping higher fees on foreign shippers from countries such as China. Supporters say the moves are necessary to increase US-flagged carriers so the military has a larger cargo fleet in a prolonged conflict. Read more here (subscription required).
HHS Releases AI Strategy, United by New OneHHS Approach, NextGov/FCW
The Department of Health and Human Services has set up a plan for AI implementation across the agency that relies on five pillars of effort: ensuring governance and risk management; designing infrastructure for user needs; promoting workforce development and burden reduction; fostering research through gold-standard science; and enabling public health delivery modernization. Read more here.
Upcoming Presentations
WEBINAR: Small Business Contracting & Subcontracting, December 16, 2025, Meghan F. Leemon
WEBINAR: Nuts, Bolts, and Beyond: To Be a Government Contractor, January 15, 2026, Eric Valle
CONFERENCE: Warfighting at Warp Speed: Why Defense Contractors Must Track the DOW’s Acquisition Overhaul, January 20, 2026, Josie Farinelli
PM WEBINAR: Warfighting at Warp Speed: Why Defense Contractors Must Track the DOW’s Acquisition Overhaul, January 28, 2026, Lauren Brier, Josie Farinelli
MERGERS & ACQUISITIONS / GOVERNMENT CONTRACTS
Upcoming Presentations
TRAINING: Mergers & Acquisitions in Government Contracting: Novations and Recertification, January 15, 2026, Daniel Figuenick, III, Emily A. Reid
TRAINING: Insights on the Regulations Pertaining to Novation’s and How It Impacts Company Value, February 11, 2026, Isaias “Cy” Alba, IV, Abigail “Abby” L. Baker
Bipartisan Bill Would Set Guardrails On Employers’ AI Use, Law360
A bipartisan coalition of lawmakers introduced legislation Wednesday that mandates employers include human oversight when using automated decision-making software, regularly test their tools and disclose to workers when they’re in play. Read more here (subscription required).
HHS Adds New Conditions to Telework for Employees with Disabilities, Government Executive
The Health and Human Services Department is placing new requirements on employees with disabilities who request telework as a reasonable accommodation, according to a policy document that hasn’t been widely shared with the workforce and has prompted union outcry. All requests for telework, remote work, or reassignment must now be approved by an official at the assistant secretary level or above, rather than a supervisor, pursuant to the document obtained by Government Executive dated Sept. 15, 2025, and signed by Deputy Assistant Secretary for Human Resources and Chief Human Capital Officer Thomas J. Nagy Jr. Read more here.
Upcoming Presentations
CONFERENCE: 2026 Employment Law Rescue Guide for Contractors, January 28, 2026, Nichole D. Atallah
General Services Administration (GSA) News Release: Next Phase of GSA’s OASIS+ Contract Enabling Procurement Consolidation through Expanded and Improved Offerings
On December 4, GSA announced the launch of OASIS+ Phase II, advancing its next-generation, governmentwide professional services contract program to further streamline procurement and consolidate buying. With this expansion, OASIS+ will be continuously open across 13 combined total service domains. Phase II adds five new domains to all six OASIS+ contracts, creating more pathways for agencies to access integrated, best‑in‑class services and for industry partners to compete. Read more here.
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