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Sam Finnerty and Cy Alba Discuss Procurement Overhaul with Bloomberg Government, PilieroMazza News, Samuel S. Finnerty, Isaias “Cy” Alba, IV
Transparency into major system acquisitions by federal agencies could be a casualty of cuts to procurement regulations proposed by the agency council that coordinates how the government buys goods and services. Suggested deletions from the Federal Acquisition Regulation (FAR) will make executive branch agencies more vulnerable to financial and litigation risk when purchasing goods and services from the private sector[. . .]. Read more here.
The Revolutionary FAR Overhaul: What Government Contractors Need to Know, PilieroMazza Client Alert, Samuel S. Finnerty
On May 6, 2025, the Federal Acquisition Regulatory Council (FAR Council) published draft revisions to the Federal Acquisition Regulation (FAR) as part of a sweeping, phased update known as the Revolutionary FAR Overhaul (RFO). The initial draft revisions—covering FAR Parts 1, 34, and 52—are now open for public comment through September 30, 2025, at 12:00 PM EST. However, in a major break from traditional practice, federal agencies are being directed to begin immediate adoption of the draft text through FAR deviations. This allows new procurement standards to take hold before the conclusion of formal rulemaking—raising serious questions about government contractor input, regulatory stability, and transparency. Read more here.
General Services Administration (GSA) News Release: GSA Unveils OneGov Strategy to Transform How the Government Buys Goods and Services
On April 29, GSA announced the launch of OneGov Strategy to modernize the purchase of goods and services. During the first phase, agencies will have more access to IT tools with standardized terms and pricing, which will have benefits for Original Equipment Manufacturers by providing a more direct and predictable engagement model. Read more here.
Department of Defense Memoranda:
- Army Transformation and Acquisition Reform. On April 30, DOD issued a memorandum directing the Secretary of the Army to implement a comprehensive transformation strategy to transform and streamline its strategy and force structure, eliminate wasteful spending, reform acquisition, and modernize inefficient defense contracts. Read more here.
- Pilot Program for Anything-as-a-Service (AaaS) Contracts or Agreements. On May 1, DOD issued a memorandum establishing a pilot program to utilize AaaS to fulfill DOD mission requirements for FAR-based contracts and Other Transaction Agreements (OTAs). Read more here.
- Release of Validation Response Schema Version 4.3.1 for Enterprise Data Standards. On May 2, DOD issued a memorandum providing a notification of the release of Validation Response Version 4.3.1 for Enterprise Data Standard and requiring systems to be updated by November 15, 2025. Read more here.
Small Business Administration (SBA) Office of Inspector General (OIG) Report: Eligibility of PPP Loans Exceeding Maximum Size Standards
On May 1, SBA’s OIG issued a report to determine whether the SBA made Paycheck Protection Program (PPP) loans in accordance with program size standards. The OIG identified that 79 of 355 exceeded the maximum size standard. Read the full report here.
GOP Releases Text of $150 Billion Defense Increase Package, Bloomberg Government
Republicans have released the text of a $150 billion defense package as part of a sweeping tax-cut and spending framework central to the party’s priorities this year. Read more here (subscription required).
Record Small Business Contracts Axed in Trump’s First 100 Days, Bloomberg Government
The number of small business contractors issued work cancellation notices has surged to record levels this year as the Trump administration executes its cut-and-consolidate initiatives. Read more here (subscription required).
Upcoming Government Contract Presentations
TRAINING: Unlocking the Secrets of Debriefings, May 15, 2025, Ryan Boonstra, Kelly A. Kirchgasser
INTELLECTUAL PROPERTY & TECHNOLOGY RIGHTS
OMB Issues Memoranda on Use and Acquisition of AI by Federal Agencies, Part 2: What It Means for Government Contractors, PilieroMazza Blog, Isaias “Cy” Alba, IV, Jacqueline K. Unger, Joseph P. Loman, Ryan Boonstra
In Part 2 of this series, we look at OMB Memorandum M-25-22, which addresses the procurement of AI by federal agencies. As noted in Part 1, the memos implement Executive Order 14179, “Removing Barriers to American Leadership in Artificial Intelligence,” issued by President Trump on January 23, 2025, and rescinds and replaces prior OMB memos issued by President Biden’s administration addressing the same. Like M-25-21, M-25-22 marks a significant shift in how federal agencies acquire and integrate AI—highlighting what government contractors, especially those in IT, data science, and emerging technologies, must do now to prepare. Read more here.
Department of Defense (DOD) News Release: DOD Announces Publication of the Intellectual Property (IP) Guidebook for DOD Acquisition
On May 1, DOD announced the release of its IP Guidebook for DOD Acquisition. The Guidebook provides guidance to the acquisition industry to aid in the development, execution, and management of IP Strategies aimed at supporting the acquisition life cycle. Read more here.
Office of Personnel Management (OPM) Memorandum: Initial Guidance on President Trump’s Executive Order (EO) Strengthening Probationary Periods in the Federal Service
On April 28, OPM issued a memorandum implementing the Trump Administration’s EO issued on April 24. This memorandum includes questions and answers regarding the new probationary requirements and provides sample documents for agency certification and notifications to current and former employees. Agencies will be required to submit an initial report to OPM “detailing their plans for the implementation of the EO” by May 16. Read more here.
Federal Employees Removed by Trump Would Have Easier Pathway Back to Government Service Under Democratic Bill, Government Executive
A pair of bills would seek to give hiring preference to axed feds and to standardize the length of probationary periods for government workers, as the administration has sought to fire those individuals who have less civil service job protections. Read more here.
Judge: Trump’s National Security Reasoning for Anti-Union EO Was ‘Pretext for Retaliation’, Government Executive
A federal judge on Monday wrote that President Trump’s controversial invocation of a provision of the 1978 Civil Service Reform Act to strip two-thirds of federal employees of their collective bargaining rights on national security grounds was “mere pretext” for retaliating against unions resistant to his workforce policies. Even when taken at face value, U.S. District Judge Paul Friedman said the White House did not meet the evidentiary bar to prove that collective bargaining was incompatible with national security considerations for the majority of federal agencies. Read more here.
NASA Preparing for Steep Workforce Cuts but Hopeful It Can Avoid More Layoffs, Government Executive
As NASA ramps up plans to return to the moon and, eventually, Mars, it is moving forward with plans to shrink its workforce by incentivizing employees to leave the government. The agency is still planning for lunar missions and to keep all of its centers open, though it will likely do so with fewer employees. Read more here.
Despite Return-to-Office Deadline, Some VA Employees May Still Work Remotely Because There’s Not Enough Workspace, Government Executive
Roughly 100,000 Veterans Health Administration employees will be required to work fully from an office, but an internal April 16 presentation obtained by Government Executive shows that the agency may not have enough workspace for them. Veterans Health Administration employees who live within 50 miles of federal office space must begin working fully in person by May 5 if they’re not already, but agency officials said there’ll be leniency if there’s not enough workspace. Read more here.
DHS Abruptly Ends Flexible Work Agreements, Federal News Network
The Department of Homeland Security abruptly ended alternate and flexible work arrangements on Sunday, requiring most employees to return to a five-day, in-person schedule starting Monday, April 28. DHS employees faced disciplinary measures, “up to and including removal,” for not immediately complying with the new schedule policy. Read more here.
Upcoming Labor & Employment Presentations
TRAINING: Labor Rules & Regulations: Federal Market Compliance, May 21, 2025, Nichole D. Atallah
PM WEBINAR: Multijurisdictional Employers, Part 2: 2025 State-by-State Updates on Non-Compete and Non-Solicitation Agreements, June 5, 2025, Sarah L. Nash, Zachary S. Stinson
CONSTRUCTION / LABOR & EMPLOYMENT
Department of Labor (DOL) News Release: DOL Seeks Input from Building, Large-Scale Construction Contractors to Set Prevailing Wages, Fringe Benefits in Houston Area
On April 28, DOL issued a news release requesting employers, stakeholders, and others in the construction industry located in Southeast Texas to provide feedback and contribute to establishing prevailing wage rates and fringe benefits for construction workers on federally funded and assisted projects. Read more here.
AUDITS & INVESTIGATIONS / BUSINESS & TRANSACTIONS
Government Accountability Office (GAO) Report: Fraud in Federal Programs: FinCEN Should Take Steps to Improve the Ability of Inspectors General to Determine Beneficial Owners of Companies
On April 28, GAO released a report detailing the problems with fraud across federal programs, alleged to be exacerbated by private companies that conceal their beneficial ownership, increasing the risk of fraud. GAO recommends that the offices of inspectors general have greater access to the beneficial ownership information registry to facilitate their audits and investigations. The full report is available here.
New York’s Latest Cyber Rules Pressure Small Companies, Vendors, Bloomberg Government
As another cybersecurity compliance deadline hits New York, the impact may be most deeply felt by smaller companies, as well as vendors and other businesses outside the financial sector that technically aren’t within the scope of the regulation. Read more here (subscription required).
‘Just Wait’ to See How CISA Reforms Play Out, DHS Head Tells Cyber Community, NextGov/FCW
Homeland Security Secretary Kristi Noem told a crowd of hundreds of cybersecurity practitioners Tuesday that, despite headlines about significant cuts being levied against the Cybersecurity and Infrastructure Security Agency, the cyber community should look forward to new changes that will make the nation’s cyber defense agency more robust. DHS Secretary Kristi Noem has vowed to rework America’s core cyber defense agency amid GOP accusations of conservative censorship. Many in the cyber community have deemed the reductions a national security risk. Read more here.
Pentagon’s Innovation Arm Looks Beyond Acquisition Reform to Speed Commercial Tech Buying, Defense One
DOD’s cyber verification process for software can be a costly chokepoint. While the Defense Department must ensure the software it puts on “government systems is secure in the event of various and even more sophisticated attacks,” the potentially yearslong process of getting an authority to operate is “a tremendous barrier in terms of the amount of time and cost it takes,” Liz Young McNally, the Defense Innovation Unit’s deputy director for commercial operations, said Wednesday at the Apex Defense forum. Read more here.