The Weekly Update recaps recent legislative and regulatory updates affecting
government contractors and commercial businesses.
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Trump Seeks to Unilaterally Cancel $5 Billion in Foreign Aid, Bloomberg Government
President Donald Trump is seeking to unilaterally cancel almost $5 billion in foreign aid through a “pocket rescission,” a legally dubious maneuver aimed at subverting Congress. Read more here (subscription required).
DOD Watchdog Urges Review of Ukraine Contract Costs, Law360
A U.S. Department of Defense watchdog said in a report that a review of 11 contracts to provide Ukraine security assistance worth $5.6 billion found that contracting officers for six of them failed to maintain all the required data used to determine that prices were appropriate. Read more here (subscription required).
Upcoming Government Contract Presentations
PM WEBINAR: How the Boards of Contract Appeals Work—And Why It Matters for Your Bottom Line, September 9, 2025, Lauren Brier, Josie Farinelli
SEMINAR: One Big Beautiful Bill Act and Beyond: The Tax and Tariff Landscape for Government Solutions Providers, September 10, 2025, Antonio R. Franco
TRAINING: Unlocking the Secrets of Debriefings, Government Evaluation of Proposals and Protests, September 11, 2025, Katherine B. Burrows, Eric Valle
PM WEBINAR: Overcoming the Compliance Minefield of Cost-Reimbursement Contracts, Part 1: Preparing for a Surge in DCAA Audit Activity, September 16, 2025, Isaias “Cy” Alba, IV
PM WEBINAR: The Buy American Act and Trade Agreements Act: What Government Contractors Need to Know, September 17, 2025, Jacqueline K. Unger, Abigail “Abby” Finan
PM WEBINAR: Decoding the FAR Part 6 Rewrite: Implications for Small Business Contracting and the Rule of Two, September 18, 2025, Isaias “Cy” Alba, IV
TRAINING: Joint Venture and Mentor-Protege Bidding Strategies, October 2, 2025, Peter B. Ford, Meghan F. Leemon
PM WEBINAR: Managing the Financial Impact of Tariffs on Your Government Contract, October 7, 2025, Jacqueline K. Unger, Ryan Boonstra
PM WEBINAR: Overcoming the Compliance Minefield of Cost-Reimbursement Contracts, Part 2: Mastering DCAA Audits in Cost-Plus-Fixed-Fee Contracts, October 14, 2025, Isaias “Cy” Alba, IV
PM WEBINAR: Avoiding Common Teaming and Subcontracting Pitfalls, October 16, 2025, Jon Williams
TRAINING: Past Performance: How to Use Yours, Benefit from Others’, and Defend It from Attacks, October 28, 2025, Daniel Figuenick, III, Abigail “Abby” Finan
Upcoming GSA Federal Supply Schedules Presentations
PM WEBINAR: Key Changes in GSA Schedule Contracting: What You Need to Know, October 2, 2025, Jon Williams
Federal Acquisition Regulation (FAR) Model Deviation Text for FAR Parts 28, 30, and 48
On August 28, the FAR Council released the model deviation text for the following FAR Parts:
- FAR Part 28, Bonds and Insurance. FAR Part 28 was updated with plain language, though the content and statutory requirements are mostly unchanged. The General Services Administration’s (GSA) memorandum and class deviation fully incorporating the same into all GSA procurements are available here and will be effective November 3, 2025. Informal feedback is due October 14, 2025.
- FAR Part 30, Cost Accounting Standards Administration. FAR Part 30 was restructured into four subparts: (1) General; (2) Presolicitation; (3) Evaluation and Award; and (4) Postaward. FAR Part 30 retains statutory requirements but has been updated for clarity and relevance. Alternate 1 of clause 52.230-1 was removed as obsolete. The GSA memorandum and class deviation fully incorporating the same into all GSA procurements are available here and will be effective November 3, 2025. Informal feedback is due October 14, 2025.
- FAR Part 48, Value Engineering. FAR Part 48 removes most of the original language. Prescriptive content was moved to relevant clauses. Obsolete sections and definitions were removed. The GSA memorandum and class deviation fully incorporating the same into all GSA procurements are available here and will be effective November 3, 2025. Informal feedback is due October 14, 2025.
Department of Labor (DOL):
- Direct Final Rule (DFR): Rescission of Nondiscrimination and Equal-Opportunity Provisions of the Workforce Investment Act (WIA): On August 28, DOL published a DFR confirming the effective date of September 2, 2025, for the rule rescinding the regulations that implemented the nondiscrimination and equal opportunity provisions of WIA. The DFR is available here and will be effective September 2, 2025.
- News Release: US DOL Promotes AI Literacy Across the American Workforce: On August 26, DOL announced that its Employment and Training Administration issued guidance to states on how to use Workforce Innovation and Opportunity Act grants to bolster artificial intelligence literacy and training across the public workforce system. Read more here.
Trump Orders More Agencies to Nix Collective Bargaining Agreements, Federal News Network
In a new executive order, Trump added more federal agencies to his list slated for collective bargaining cancellations “to enhance national security.” Read more here.
Appeals Court Will Reconsider Decision to Allow Trump’s Anti-Union Order to Take Effect, Government Executive
A federal appeals court in California this week signaled that it may revisit a three-judge panel’s decision earlier this month to allow agencies to implement President Trump’s executive order aimed at stripping two-thirds of the federal workforce of their collective bargaining rights. The announcement comes as the Trump administration has seemingly reneged on promises to hold off on fully implementing the edict until lawsuits seeking to block the order are complete. Read more here.
The State Department Laid Them Off, Then It Promoted Them, Government Executive
Every year, the State Department completes a thorough process involving multiple layers of review to determine who in the foreign service will get promoted. For some of the employees approved for higher-ranked roles this year, the news came as a surprise: just a month ago, they were laid off by the department. Read more here.
Upcoming Labor & Employment Presentations
CONFERENCE: Impact of the Trump Administration on Government Contracts, September 12, 2025, Nichole D. Atallah
PM WEBINAR: Multijurisdictional Employers, Part 4: Marijuana and Other Drug Testing in the Workplace, September 25, 2025, Sarah L. Nash, Sara N. Strosser
TRAINING: Labor Rules & Regulations: Federal Market Compliance, October 22, 2025, Nichole D. Atallah
Department of Defense (DOD) Class Deviation: Use of the Clause on Contractor Compliance With the Cybersecurity Maturity Model Certification (CMMC) Level Requirement
On August 25, DOD issued a memorandum, effective immediately, ensuring contracting officers do not use the contract clause at Defense Federal Acquisition Regulation Supplement (DFARS) 252.204-7021, Contractor Compliance With the Cybersecurity Maturity Model Certification Level Requirement, in new solicitations and contracts. Read more here.