The U.S. Small Business Administration (“SBA”) has extended the comment periods for its proposed overhaul of small business size standards and its accompanying Revised Size Standards Methodology by 60 days, from September 21 to November 20, 2026.
As we discussed in our prior post, SBA’s proposed rule would
Continue Reading SBA Extends Comment Period on Proposed Small Business Size Standards to November 20On August 20, 2026, the U.S. Small Business Administration (“SBA”) issued a proposed rule that would reset small-business size standards across the economy and a companion white paper proposing a new methodology for calculating them. The proposed rule—Small Business Size Standards, 91 Fed. Reg. 53,741—would establish new size standards for 338 industry groups and industries. The accompanying white paper—Revised Size Standards Methodology, 91 Fed. Reg. 54,096—supplies the analytical framework SBA used to derive the standards in the proposed rule. Notably, SBA calculated the proposed standards using a methodology that is itself out for notice-and-comment, with both comment periods closing the same day, September 21, 2026.
Continue Reading SBA Proposes Overhaul of Size Standards That Would Reclassify Tens of Thousands of Contractors as “Small”
The Government Accountability Office recently issued a report on the Department of Defense’s civilian workforce reductions. It offers a concrete record of how DoD has reduced staffing, where those reductions have occurred, and how the Department has assessed their effects. GAO’s report matters not only as a workforce-management review, but also as a practical resource for companies that depend on DoD procurement, oversight, audit, logistics, finance, and program-management functions. For defense contractors, the report suggests that delays, capacity constraints, and operational friction may persist—and that these issues are likely to receive increased congressional and internal DoD attention.
Continue Reading GAO Scrutinizes DoD Civilian Workforce Cuts: What the Report Means for Federal Contractors
The Armed Services Board of Contract Appeals’ (ASBCA) decision in Lockheed Martin Aeronautics Co., ASBCA No. 63621, reinforces a critical principle for government contractors: contract performance requirements operate independently of cost accounting classifications. Contractors cannot avoid substantive FAR and DFARS obligations—here, U.S.-flag transportation requirements—by treating costs as
Continue Reading Indirect Doesn’t Mean Exempt: ASBCA Rejects Cross‑Motions Over U.S.-Flag Transportation CostsOn March 26, 2026, President Trump issued an Executive Order (EO) titled “Addressing DEI Discrimination by Federal Contractors,” the latest in a series of Executive Orders and related actions by the Administration targeting what it views as unlawful Diversity, Equity, and Inclusion (“DEI”) related practices. Most notable about
Continue Reading New “Addressing DEI Discrimination” Executive Order: What Federal Contractors Need to KnowA recent decision from the Armed Services Board of Contract Appeals (ASBCA) is a timely reminder that, when it comes to stop‑work orders, the clause the government actually invokes—not the one it later wishes it had—can be outcome‑determinative. In Wolverine Tube, Inc., ASBCA No. 63877 (Jan. 22, 2026), the Board rejected the Air Force’s attempt to retroactively recharacterize a stop‑work order and held that the order expired by its own terms after 90 days. Although the contractor did not obtain summary judgment on most of its claimed costs, the decision breaks new ground on how protest-related stop-work orders operate, what happens when they lapse, and how far the government can go in arguing that “stop work” really meant “stop incurring costs forever.”
Continue Reading Stop-Work Means Stop Work (…Until It Doesn’t): Lessons from Wolverine TubeThe Trump Administration continues to focus on procurement reform aimed at increasing acquisition efficiency, including through the “Revolutionary FAR Overhaul” and reinforced preference for commercial products. Now, with the House Armed Services Committee (HASC) introducing a defense procurement reform bill, it is clear that HASC leadership is also targeting increased efficiency as a key goal of the Fiscal Year 2026 National Defense Authorization Act (FY26 NDAA). We cover the bill’s key proposals and their potential impact on defense contractors below.
Continue Reading SPEEDing up Procurement?: House Armed Services Bill Seeks to Reform Defense Acquisition
The Government Accountability Office (“GAO”) released a report on the Defense Contract Audit Agency’s (“DCAA”) past and future use of private-sector, independent public accountants to augment its auditor workforce. The initiative—approved under Section 803 of the Fiscal Year (“FY”) 2018 National Defense Authorization Act (“NDAA”)—began in fiscal year 2020 and was originally envisioned by Congress as a tool to reduce DCAA’s backlog of incurred cost audits. But, as GAO noted, DCAA had largely eliminated its audit backlog by the end of FY 2018, primarily through its reliance on risk-based sampling methodology, which reduced the number of audits DCAA was required to complete.
Continue Reading GAO: DCAA Built a Valuable Bench of Independent Public Accountants, Now What?
On April 20th, a bipartisan, bicameral group of lawmakers, including Senator Mark Kelly (D-Ariz.) and Senator Todd Young (R-Ind.) in the Senate and Representative John Garamendi (D-Calif.) and Representative Trent Kelly (R-Miss.) in the House, reintroduced the Shipbuilding and Harbor Infrastructure for Prosperity and Security for America Act of 2025 (the “SHIPS Act” or the “Act”). The SHIPS Act’s sponsors describe the bill as a “comprehensive approach to revitalizing the U.S. Merchant Marine.” It aims to: (1) establish national oversight and consistent funding for U.S. maritime policy; (2) make U.S.-flagged vessels more commercially competitive through de-regulation; (3) rebuild the U.S. shipyard industrial base; and (4) expand and strengthen the maritime labor force. It also sets a goal for establishing a fleet of 250 U.S.-flagged vessels in international commerce.
Continue Reading Reintroduced SHIPS Act Signals Continued Momentum for Domestic Maritime InvestmentSince January 20, the Trump administration has taken numerous executive actions that impact federal government contractors and grant recipients. In just a single day last week, the Trump administration issued a series of EOs and presidential memoranda that, among other things, seek to reform the defense acquisition system, bolster the U.S. maritime industry, and streamline foreign military sales. The potential impact of these changes to Department of Defense (“DoD”) procurement policy are relatively self-evident.
At the same time, the Trump administration has taken various steps to reorganize and reduce the federal workforce, including significant changes to the DoD civilian workforce. The potential effects of these personnel policies are less obvious but may be equally meaningful for defense contractors. This blog focuses on one such executive action, Executive Order 14210 (titled Implementing the President’s ‘‘Department of Government Efficiency’’ Workforce Optimization Initiative) and its potential implications for the defense industrial base.
Continue Reading DoD is Shrinking its Civilian Workforce: What Contractors Should Know Now