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.
_____________________________________________
Office of Federal Procurement Policy (OFPP) Proposed Rules:
On March 20, OFPP published two proposed rules and requests for comments. Comments close April 20, 2026.
- Conformance of Cost Accounting Standards to Generally Accepted Accounting Principles for CAS 407 Use of Standard Costs for Direct Material and Direct Labor. This proposed rule will change the Cost Accounting Standards to conform CAS 407 to Generally Accepted Accounting Principles. The rule is available here.
- Increase of Monetary Thresholds and Other Matters Related to Cost Accounting Standards Program Requirements. This proposed rule will increase the CAS thresholds. The rule is available here.
The White House: President Donald J. Trump Unveils National AI Legislative Framework
On March 20, the Trump Administration issued a comprehensive national legislative framework that addresses the most pressing policy topics that AI presents. The framework addresses six key objectives. The full policy is available here. Read more here.
Federal Acquisition Regulation (FAR) Updated Model Deviation Text for FAR Parts 1, 5, 10, 22, 25, and 52
On March 16, the FAR Council released updated model deviation text for the following FAR Parts: 1 Federal Acquisition Regulations System; 5, Publicizing Contract Actions; 10, Market Research; 22, Application of Labor Laws to Government Acquisitions; 25, Foreign Acquisition; and 52, Solicitation Provisions and Contract Clauses. The Parts are updated to conform with the changes to the codified FAR as outlined in FAR Case 2025-007, Trade Agreements Thresholds, Final Rule, effective March 13, 2026. Read more here.
Small Business Administration (SBA) News Release: SBA Celebrates Success of First-Ever Made In America Matchmaking Expo for Suppliers and Manufacturers
On March 19, SBA announced the results of its inaugural 2026 Supplier Matchmaking Expo, a first-of-its-kind event held last week in partnership with the National Association of Manufacturers (NAM) in Charlotte, North Carolina. The Expo was designed to advance the Made in America agenda by helping large producers connect with small domestic suppliers. More than 675 small business suppliers participated, along with 35 large industrial buyers. Read more here.
Government Accountability Office (GAO) Report: U.S. Army Corps of Engineers: Continued Use of Other Transaction Agreements for Civil Works Research and Prototypes
On March 19, GAO released a report detailing its review of the U.S. Army Corps of Engineers’s use of OTAs for research and development to support its civilian civil works missions and authorities. The Water Resources Development Act of 2018, as amended in 2022 (the 2022 act), authorized the U.S. Army Corps of Engineers to use other transaction (OT) agreements to carry out certain projects to support research activities for its Civil Works program. In 2024, the Corps awarded its first such agreement for the design of a prototype flume to test the operation of locks and other structures. The Corps expects the design for this flume to be completed in April 2026 and the prototype to be assembled as a follow-on project. The Corps also awarded three additional agreements of this type in 2025 to research algal blooms that can affect water infrastructure. Read more here.
War Dept Shifting From AI Strategic Enablement to Delivery Focus, Says CDAO, GovCon Wire
The Department of War is charting a new course with artificial intelligence: moving from a mode of strategic enablement to disciplined delivery. The Pentagon wants to put “key critical [AI] capabilities” in the hands of warfighters as fast as possible, according to Cameron Stanley, who was appointed chief digital and artificial intelligence officer for the entire U.S. warfighting enterprise in January. Read more here.
From Strait of Hormuz to Factory Floor, Iran Conflict Reshaping Contract Work, Federal News Network
Ongoing U.S. military operations in the Middle East are stretching supply chains, increasing demand for munitions and intelligence, and raising new questions about how long industry can sustain the pace without supplemental funding. Behind every deployment, contractors are providing the logistics, technology, and support that make operations possible. Here’s a look at what this moment means for the industry. Read more here.
Upcoming Presentations
TRAINING: Small Business Contracting & Subcontracting, April 15, 2026, Eric Valle
WEBINAR: Tariffs in Government Contracting, April 23, 2026, Jacqueline K. Unger
WEBINAR: The Buy American Act and Trade Agreements Act, May 28, 2026, Jacqueline K. Unger
Department of Labor (DOL) News Release: DOL’s OSHA Cares Initiative Strengthens Customer Service, Expands Compliance Assistance
The DOL’s Occupational Safety and Health Administration today announced the launch of its OSHA Cares initiative, an agency-wide effort focused on helping businesses meet federal workplace safety requirements, while also building strong, successful safety and health programs that benefit employers and workers. Read more here.
DOL News Release: DOL to Host Educational Seminar for Agricultural Industry Employers, Workers, Other Stakeholders
The DOL’s Wage and Hour Division will hold a hybrid in-person and virtual agricultural seminar to provide guidance on federal laws governing agricultural industry employment for growers, farmers, shippers, contractors, farm labor contractors, buyers, and agricultural workers nationwide. Read more here.
Office of Personnel Management (OPM) Memorandum: Modernizing HR Services by Establishing the OPM HR Shared Service Center
President Trump has made it a key priority to “eliminat[e] bureaucratic duplication and inefficiency” and save taxpayer money. As part of its “efforts to maximally consolidate and coordinate Federal human resources (HR) services and IT platforms governmentwide to create efficiencies, enhance quality, and reduce redundancies,” the OPM is leading the effort to improve the quality and efficient delivery of HR services across the government. The “Federal HR 2.0” initiative will create “efficiencies in Federal human capital management and facilitating more effective management of the Federal workforce as a unified entity.” The full memo is available here.
Veterans Affairs Union Pact Restored by Judge’s Temporary Order, Bloomberg Government
The Department of Veterans Affairs must honor its collective bargaining agreement with the American Federation of Government Employees while the parties litigate the legality of its cancellation, a Rhode Island district judge ruled. Read more here (subscription required).
Upcoming Presentations
TRAINING: Labor Rules & Regulations: Federal Market Compliance, April 15, 2026, Sarah L. Nash
TRAINING: ABCs of the SCA: Critical Path Service Contract Act Training for Government Contractors, April 28-30, 2026, Nichole D. Atallah, Sarah L. Nash
Upcoming Presentations
WEBINAR: Don’t Leave Money on the Table: Unlocking Federal Contract Disputes to Increase Cost Recovery, April 3, 2026, Lauren Brier, Jonathan “Jon” R. Neri
PM WEBINAR: Contract Claims 101: The Fundamentals of Contract Administration Disputes, April 16, 2026, Josie Farinelli, Abigail “Abby” Finan, Kelly A. Kirchgasser
LITIGATION & DISPUTE RESOLUTION
86 That Grant: SBA Targets Restaurant Revitalization Fund Recipients for Recoupment, PilieroMazza Blog, Matthew E. Feinberg, Scott Stemetzki
The Restaurant Revitalization Fund (RRF) was a Congressionally-created program, administered by the U.S. Small Business Administration (SBA), under which financial grants were issued to restaurants, food stands, caterers, bars, food trucks, food carts, breweries, wineries, and other food and beverage businesses to help those companies navigate the restrictions imposed by the COVID-19 pandemic. In March 2024, the SBA Office of Inspector General issued a report, SBA’s Restaurant Revitalization Fund Program Award Practices, which suggested that approximately $6.7 Billion of the $28.6 Billion in grants issued under the program were awarded to ineligible entities. In response to the OIG report, SBA management committed to seeking recovery of excess funds paid to allegedly ineligible recipients by May 30, 2025. SBA appears to have missed that deadline, because, recently, SBA issued letters to some recipients of grants rescinding their eligibility for the program and demanding full or partial repayment of the grants. In many cases, the notices were a shock to grant recipients who went through the grant approval process and submitted their post-award report over two years ago. Now, they face a daunting 30-day deadline for repayment of hundreds of thousands or even millions of dollars the company no longer has. Companies that received grants under the RRF program should be prepared to timely appeal and, if necessary, litigate SBA rescission letters in order to preserve the companies’ rights to the funds and the companies’ financial bottom line. Read more here.
Government Accountability Office (GAO) Report: Quantum Computing: Updating the National Strategy Could Promote U.S. Leadership
On March 18, GAO released a report detailing its review of federal efforts regarding quantum computing and cryptography. This report addresses (1) the extent to which the quantum computing component of the national quantum strategy addresses GAO’s desirable characteristics of a national strategy and (2) the status of federal efforts to develop and assess the U.S. quantum information science workforce. GAO recommends that the Office of Science and Technology Policy, in coordination with the Subcommittee on Quantum Information Science agencies, augment and update the national quantum strategy, which includes quantum computing, to address the desirable characteristics of a national strategy. Read more here.
Why Assessment Integrity Is the Hidden Mission Enabler for CMMC 2.0, Federal News Network
Advancing cybersecurity maturity in the defense industrial base relies on one principle: trust. While some organizations initially view Cybersecurity Maturity Model Certification (CMMC) as avoidable or unnecessary, experience has shown that it is neither. Over time, compliance becomes a practical requirement for protecting sensitive information and continuing to operate within the defense ecosystem. That trust must extend across the system — trust in contractors to safeguard controlled unclassified information with robust guidelines, trust that certifications accurately reflect real security posture, and trust that the Defense Department can rely on assessment outcomes for mission and acquisition decisions. Read more here.
BUSINESS & TRANSACTIONS / MERGERS & ACQUISITIONS
Upcoming Presentations
TRAINING: Legal Considerations: How Best to Structure Your Company as a Federal Contractor, April 14, 2026, Isaias “Cy” Alba, IV
NATIVE AMERICAN LAW & TRIBAL ADVOCACY
U.S. Department of the Treasury Release: Treasury Publishes Two Historic Final Tribal Tax Regulations
At the December 15, 2025, meeting of the TTAC, the Department announced two final pro-growth and deregulatory tax regulations that support the prosperity of Tribal businesses and families and recognize the sovereignty of Tribal governments. The first rule implements the Tribal General Welfare Exclusion Act of 2014, which confirms that Tribes may provide assistance to their Tribal members and families that is excluded from federal income tax. Treasury’s second regulation confirms that entities wholly owned by Tribal governments and chartered under Tribal laws have the tax treatment of the Tribal government and are not subject to federal income tax. To view more information on these rules, see the Treasury’s Tribal General Welfare Fact Sheet and Consultation and Federal Feedback Summary, and Tribal Entity Fact Sheet and Consultation and Federal Feedback Summary.
Tribal Leaders Bash USDA’s Plan to Relocate Thousands of Staff and Shutter Offices, Government Executive
Agriculture’s reorganization would create inconveniences and damage relationships the tribal governments have worked hard to establish, they told the department. Tribal governments largely panned the Agriculture Department’s plan to relocate thousands of employees around the country and shutter some regional offices, saying during recent consultations the reforms would degrade long-established relationships and result in staffing shortages that negatively affect services. Read more here.
General Services Administration (GSA) News Release: GSA and NIST Partner to Boost AI Evaluation Science in Federal Procurement
On March 18, GSA announced that it is partnering with the National Institute of Standards and Technology’s Center for AI Standards and Innovation in a joint effort to strengthen how the federal government evaluates artificial intelligence models and services. Read more here.
General Services Administration (GSA) Blog: Cutting Red Tape, Strengthening Results: Early Lessons from the RFO
On March 18, GSA published a blog emphasizing that the prior version of the FAR, prior to the RFO, was growing more complex because of the addition of new rules and requirements. GSA considers the RFO the most significant simplification of acquisition regulations in more than 40 years and returning the FAR to its statutory foundations while modernizing how agencies acquire goods and services. This blog highlights what the early results of the RFO look like. Read more here.
General Services Administration (GSA) Blog: Multiple Award Schedule (MAS) Blogger, Advanced Notice for MAS Refresh 31 and Upcoming Mass Modification
On March 19, GSA updated its January 12 blog to note that GSA will not be including the proposed AI clause, GSAR 552.239-7001, in the upcoming MAS Refresh 31. Comments on the proposed AI Clause are due April 3. Read more here.
Section 508 Report Eyes Acquisition ‘Lever,’ Federal News Network
With most federal agencies still struggling to comply with technology accessibility requirements, the General Services Administration sees an opening to make acquisition a “primary lever” in enforcing Section 508 of the Rehabilitation Act. Read more here.
Small Business Administration (SBA) Direct Final Rule: Program Fraud Civil Remedies Act Regulations Statutory Updates
On March 19, SBA published a direct final rule and request for comments implementing changes made to the Program Fraud Civil Remedies Act of 1986 by the Administrative False Claims Act (AFCA) of 2023. These changes, among other things, revise the name of the administrative action from “Program Fraud Civil Remedies” to “Administrative False Claims” and increase the threshold for a claim from $150,000 to $1,000,000. The AFCA mandates that the SBA issue regulations, and SBA is adopting statutory requirements without change. The rule is available here. The rule will be effective May 4, 2026. Comments close April 20, 2026.
Executive Order (EO): Establishing the Task Force to Eliminate Fraud
On March 16, the President issued an EO establishing a task force to eliminate fraud in the government, blaming illegal aliens, criminals, foreign gangs, bureaucrats, State and local officials, non-governmental organizations, and ineligible providers for exploiting government programs. The task force will be required to work across federal agencies to develop measures and controls to prevent improper payments, analyze fraud trends, develop interagency information sharing, audit and investigate fraud, and ensure compliance monitoring. Read more here.
Government Accountability Office (GAO) Report: Federal Information Transparency: Action Needed to Improve Efficiency and Effectiveness and Enhance Program Integrity
On March 17, GAO released a report addressing Congress and the Executive’s steps to improve the transparency of information on federal spending and programs. However, GAO found that challenges remain in various areas and made recommendations to federal agencies and Congress to help address them. These challenges include federal spending data transparency, improper payments, federal program inventory, and Freedom of Information Act request processing. Read more here.
###