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.

_____________________________________________

 

GOVERNMENT CONTRACTS

DHS Shutdown Talks Hit a Wall as GOP Fumes, The Hill
Discussions between the White House and Democratic leaders on funding the Department of Homeland Security (DHS) have hit a wall as administration officials publicly slammed the minority party for refusing to make concessions. Read more here.

 SBA Strikes Again: New 8(a) Program Suspensions Related to Economic Disadvantage Criteria, PilieroMazza Blog, Matthew E. FeinbergMeghan F. Leemon
On February 11, 2026, the U.S. Small Business Administration issued a press release announcing that it was initiating termination proceedings and suspending over 150 Washington, D.C.-based 8(a) firms for allegedly failing to meet “economic disadvantage” eligibility criteria for the 8(a) Program. This is a bold move as traditionally proposed terminations are not also coupled with suspensions. And while the press release asserts that these firms “exceeded statutory net worth limits, adjusted gross income caps, or total asset limits,” the notice these firms received suggests that these firms “may” no longer be eligible. Contractors are entitled to respond and explain why the proposed grounds do not justify termination. Understanding the regulations and calculations is critical. SBA’s move to propose termination while simultaneously suspending 8(a) firms based on the program’s economic disadvantage criteria shows SBA’s continued scrutiny of the 8(a) Program and the need for 8(a) firms to understand and maintain eligibility compliance. Read more here.

Bloomberg Government: Cy Alba Warns DOD’s Direct OEM Buying Trend Could Raise Costs and Undermine ITVAR Competition, PilieroMazza News, Isaias “Cy” Alba, IV
A recent report by Bloomberg Government highlights a major shift in federal IT procurement: billions of dollars in work are moving from IT value-added resellers (ITVARs) and integrators to original equipment manufacturers (OEMs) under new Department of Defense acquisition strategies. Read more here.

Warfighting at Warp Speed, Part 4: DFARS Overhaul, PilieroMazza Blog, Lauren BrierJosie FarinelliAdel Mansour
In November 2025, the Department of War (DOW) announced its blueprint for its Acquisition Overhaul, and savvy defense contractors took note of DOW’s plan to realign its processes with its goals—namely, accountability, speed, and industry investment. In concert with the broader Revolutionary FAR Overhaul (RFO), DOW is now implementing a sweeping rewrite of the Defense Federal Acquisition Regulation Supplement (DFARS). In this blog, we provide an overview of how the DFARS rollout will occur and some key insights on a few of the class deviations that are already in effect—many of which are changing compliance obligations for government contractors now, not later. For more information on the DOW Acquisition Overhaul, click here to access our webinar on the topic, click here for Parts 1-3 of this series, and for more on the RFO, click here. Read more here.

Federal Acquisition Regulation (FAR) Proposed Rule: Prohibition on Certain Semiconductor Products and Services
On February 17, Department of Defense, General Services Administration, National Aeronautics and Space Administration, and the Office of Federal Procurement Policy published a proposed rule and request for comments regarding the prohibition of executive agencies from procuring or obtaining certain products and services that include covered semiconductor products or services. This rule implements the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023 and will be effective December 23, 2027. The rule is available here. Comments will close April 20, 2026.

OMB Seeks to Once Again Empower Agency CIOs, Federal News Network
The Office of Management and Budget is once again trying to empower agency chief information officers around IT buying decisions. Federal Chief Information Officer Greg Barbaccia told agencies recently that OMB is finalizing an effort to “make sure you have ultimate decision-making authority over all of your agency’s IT acquisitions. We will be requesting contract information from you and to make sure your contracts include appropriate clauses on providing utilization rates and pricing information.” Read more here.

SBA Notification: 7(a) Alternative Base Rate Options
On February 10, SBA published a notice introducing alternative base rate options for use with variable interest rate loans made under the 7(a) Loan Program. The alternative base rate options are also available for use under any 7(a) pilot loan programs, unless expressly prohibited. The notice is available here and will be effective March 1, 2026.

CIA Emphasizes Speed Under New Acquisition Framework, Federal News Network
The CIA is emphasizing speed under a new acquisition framework aimed at tightening partnerships between the spy agency and private technology companies. Read more here.

How Far Can DOD Contract Enforcement Go Without Undercutting Small‑Business Programs?, Federal News Network
Small business set‑asides are mandated by statute, anchored in the rule of two, and central to competition in the defense industrial base. The Secretary’s memo adds new tests for mission necessity, subcontracting compliance, and market pricing — all under compressed deadlines. Read more here.

Upcoming Presentations

PM WEBINAR: DCAA’s Annual Update, February 24, 2026, Isaias “Cy” Alba, IV

CONFERENCE: Build Your Dream Advisory Team, February 25, 2026, Isaias “Cy” Alba, IV

CONFERENCE: Managing the Financial Impact of Tariffs on Your Government Contracts, March 4, 2026, Jacqueline K. UngerRyan Boonstra

SEMINAR: Government Contractors and Tariff Challenges: Strategies for Success, March 11, 2026, Jacqueline K. Unger

CONFERENCE: Federal Small Business Update — Threats and Opportunities in the Current Environment, March 12, 2026, Lauren Brier

 

LABOR & EMPLOYMENT

Congress Gave Feds a 3-Month Break From Layoffs. A Court Decides What Happens Next, Federal News Network
Lawmakers gave federal employees a three-month reprieve from governmentwide layoffs, as part of back-and-forth budget negotiations following the longest shutdown last fall. With a continuing resolution set to expire, agencies will likely be free to proceed with mass layoffs. But next steps will be decided by a federal judge. Read more here.

Federal Employees Put Into Revived ‘Schedule F’ Category May Lose Loan Aid, Pay Incentives, Federal News Network
Federal employees who may soon lose their job protections under the Trump administration may, by extension, also lose access to additional benefits. Additional Schedule Policy/Career guidance follows the Trump administration’s final rule to strip job protections from certain career federal employees. Read more here.

Office of Personnel Management (OPM) Memorandum:

  • Implementation of Executive Orders (EOs) 14251 and 14343: On February 12, OPM issued a memorandum implementing two EOs exempting certain agencies and their subdivision from the requirements of the Federal Service Labor-Management Relations Statute if their primary function is intelligence, counterintelligence, investigative, or national security. Read more here.
  • Frequently Asked Questions (FAQs) on Telework Accommodations for Disabilities in the Federal Government: On February 11, OPM announced the release of FAQs regarding receiving telework as a reasonable accommodation for disabilities. Read more here. The FAQs are available here.

Democrats Call for 4.1% Federal Pay Raise in 2027, Federal News Network
Democratic lawmakers are calling for a substantially larger federal pay raise in 2027, with new legislation that would provide a 4.1% pay increase for civilian federal employees next year. House and Senate lawmakers reintroduced the FAIR Act, aiming to bring federal employees’ pay rates closer in line with private sector salaries. Read more here.

House Lawmakers Weigh Adding Earmarks to Labor-HHS Spending Bill, Bloomberg Government
Top members of the House Appropriations Committee are considering allowing earmarks for the Labor-HHS-Education funding bill for the next fiscal year, lifting a self-restriction on the projects set by conservatives. Read more here (subscription required).

Department of Labor (DOL) News Release:

  • Provides Regulatory Relief for Companies, Insurers in Vital Industries: Affected industries include shipbuilding, resource extraction, and defense. On February 6, DOL published a notice providing enhanced and transparent guidance for calculating the amount of securitization required by insurers writing policies under the Longshore and Harbor Workers’ Compensation Act. Read more here.
  • DOL Releases AI Literacy Framework Providing Foundational Content Areas, Delivery Principles to Guide Nationwide Efforts: On February 13, DOL’s Employment and Training Administration announced the publication of a framework for Artificial Intelligence literacy to guide nationwide AI literacy efforts across the workforce. Read more here.

Upcoming Presentations

TRAINING: Labor Rules & Regulations: Federal Market Compliance, March 18, 2026, Sarah L. Nash

CONFERENCE: Ins and Outs of the Service Contract Act, March 23, 2026, Nichole D. Atallah

CONFERENCE: DMV Legal Compliance Toolkit: Practical Insights for Multi-Jurisdictional Employers, March 24, 2026, Sarah L. Nash

CONFERENCE: You’re Fired! Legal Risks of Personnel Management for Tribally Owned Entities, March 25, 2026, Nichole D. Atallah

 

MERGERS & ACQUISITIONS

Upcoming Presentations

CONFERENCE: Plan Your Exit Strategy and Adjust Along the Way, February 25, 2026, Isaias “Cy” Alba, IV

WEBINAR: Buying or Selling: Navigating the New Landscape of 8(a) M&A Transactions, February 26, 2026, Isaias “Cy” Alba, IV

 

FALSE CLAIMS ACT / AUDITS & INVESTIGATIONS

Government Accountability Office (GAO) Report: Consumer Financial Protection Bureau (CFPB): Status of Reorganization Efforts
Since February 2025, CFPB has taken actions to reduce the size and scope of its activities and staffing. These actions included issuing stop-work orders, closing supervisory examinations, and terminating employees, contracts, and enforcement cases. Some of these actions, such as employee termination, are the subject of ongoing litigation and have not been finalized. On August 15, the United States Court of Appeals for the District of Columbia Circuit vacated the district court’s injunction that prevented CFPB from taking various personnel actions, terminating certain contracts, and other actions related to downsizing the agency. The circuit court delayed the effective date of its order to allow the plaintiffs time to request a rehearing. Read more here.

Upcoming Presentations

PM WEBINAR: PilieroMazza Annual Review: FCA Enforcement and Compliance Updates for Government Contractors—What to Watch in 2026, March 3, 2026, Jacqueline K. UngerTodd M. Reinecker

 

CYBERSECURITY & DATA PRIVACY

Department of Homeland Security (DHS) Notice: Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) Rulemaking, Town Hall Meetings
On February 13, DHS’s Cybersecurity and Infrastructure Security Agency (CISA) published a notice announcing town hall meetings to allow stakeholders the opportunity to provide input on the CIRCIA rulemaking that was issued on April 4, 2024, which will require cyber incident and ransom payment reporting for covered entities. The notice is available here, and registration is available here. Town halls will occur virtually, are scheduled to last approximately 2 hours, and registration is accepted until 5 pm ET two business days before the meeting. The town halls are as follows:

  • Chemical Sector; Water and Wastewater Sector; Dams Sector; Energy Sector; and Nuclear Reactors, Materials, and Waste Sector – March 9, 2026
  • Commercial Facilities Sector; Critical Manufacturing Sector; and Food and Agriculture Sector – March 12, 2026
  • Emergency Services Sector, Government Facilities Sector, Healthcare and Public Health Sector – March 17, 2026
  • Communications Sector; Transportation Systems Sector; and Financial Services Sector – March 18, 2026 
  • Defense Industrial Base Sector and Information Technology Sector – March 19, 2026
  • General Sessions – March 31 and April 2, 2026

Upcoming Presentations

PM WEBINAR: CMMC Mission Readiness: Navigating Growth, Costs, and Competition for Defense Contractors, March 11, 2026, Isaias “Cy” Alba, IV

###