Contractors tracking the government’s growing reliance on Blanket Purchase Agreements (BPAs) and the rollout of the Revolutionary Federal Acquisition Regulation Overhaul (RFO) should take note of Government Accountability Office (GAO)
Continue Reading RFO Consolidation Limitations Do Not Apply to BPAs, Says GAOIt’s Official: RFO Enters Formal Rulemaking
The Revolutionary FAR Overhaul (RFO) finally has moved into formal rulemaking, and it comes with a few surprises. The FAR Council completed the first phase of the RFO in September
Continue Reading It’s Official: RFO Enters Formal Rulemaking
Warp Speed Ahead: Agencies Move Quickly to Implement Anti-DEI Clause
Contractors have begun receiving modifications to existing contracts implementing the new DEI clause mandated by Executive Order 14398 “Addressing DEI Discrimination by Federal Contractors.” Shortly after the executive
Continue Reading Warp Speed Ahead: Agencies Move Quickly to Implement Anti-DEI ClauseFirst DEI Settlement Under the Civil Rights Fraud Initiative Targets Conduct Pre-Dating the Current Administration
On April 10, 2026, the Department of Justice (“DOJ”) announced a $17 million civil False Claims Act (“FCA”) settlement with IBM Corporation. This is the first FCA settlement reached under
Continue Reading First DEI Settlement Under the Civil Rights Fraud Initiative Targets Conduct Pre-Dating the Current AdministrationFCA 101: Materiality
This is the fourth blog in a series on the False Claims Act (FCA), 31 USC §§ 3729, et seq., which targets any person that knowingly submits false claims for
Continue Reading FCA 101: MaterialityThe Civilian Board of Contract Appeals Issues New Rules of Procedure for Its Adjudicatory Role in the Administrative False Claims Act
On January 28, 2026, the United States Civilian Board of Contract Appeals (CBCA) issued final rulemaking to address its role in hearing and resolving disputes under the Administrative False Claims
Continue Reading The Civilian Board of Contract Appeals Issues New Rules of Procedure for Its Adjudicatory Role in the Administrative False Claims ActDOJ’s 2025 FCA Statistics – Contractors Check Your Cybersecurity Compliance and Cost or Pricing Data
The U.S. Department of Justice (DOJ) published its 2025 False Claims Act (FCA) statistics on Friday with a record-breaking $6.8 billion in judgments and settlements last fiscal year. This was
Continue Reading DOJ’s 2025 FCA Statistics – Contractors Check Your Cybersecurity Compliance and Cost or Pricing DataShould I Appeal My Terminated Grants in District Court or the Court of Federal Claims?
In 2025, the government has canceled or discontinued billions of dollars in federal grants. Entities seeking to challenge these terminations have faced uncertainty as to which forum is appropriate for
Continue Reading Should I Appeal My Terminated Grants in District Court or the Court of Federal Claims?Bid Protests, Disputes, and Federal Contract Delays During the Government Shutdown
The federal government shut down on October 1 after annual appropriations lapsed. Pursuant to the Antideficiency Act, agencies may not incur obligations or expend funds without an enacted appropriation unless
Continue Reading Bid Protests, Disputes, and Federal Contract Delays During the Government ShutdownWhat Federal Contractors and Grant Recipients Should Know About DOJ’s Unlawful Discrimination Guidance
On July 29, 2025, US Attorney General Bondi issued a memorandum for all federal agencies titled “Guidance for Recipients of Federal Funding Regarding Unlawful Discrimination” (the Memo). The Memo follows
Continue Reading What Federal Contractors and Grant Recipients Should Know About DOJ’s Unlawful Discrimination Guidance