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Peter Terenzio

Peter Terenzio advises clients regarding the regulatory requirements that govern federal contractors and grantees. He focuses on helping clients navigate the Cost Accounting Standards (CAS) and the cost principles in FAR Part 31 and 2 CFR Part 200. He also routinely advises on Other Transaction Authority (OTA) research, prototype, and production agreements.

Peter works on accounting, cost, and pricing matters, including providing day-to-day compliance advice; assisting with responses to audits and investigations and findings of potential noncompliance; and performing internal investigations of alleged violations. He also advises on other regulatory regimes, including the complicated prevailing wage rules imposed by the Davis Bacon Act (DBA) and Service Contact Act (SCA). He has particular experience with prototype OTAs issued in cutting edge fields, including quantum computing and biotechnology.

Peter also represents contractors in disputes arising under contracts and grants. He knows how to work closely with the client's subject matter experts to prepare and submit detailed requests for equitable adjustment (REAs) to secure price or schedule relief. When contract disputes cannot be resolved amicably, he has helped clients in litigation before federal courts and the Boards of Contract Appeals.

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On February 20, 2026, the Supreme Court struck down an extensive series of tariffs imposed last year by President Trump, holding that they were not authorized under the International Emergency Economic Powers Act (“IEEPA”).  And on March 4, 2026, the United States Court of International Trade began the process of refunding certain of “the millions of entries that were subject to IEEPA,” through a process known in the international trade context as liquidating. 

These recent decisions by the Supreme Court and Court of International Trade may prompt federal contractors to consider seeking refunds of tariffs paid to import goods required to perform under their government contracts.  As we covered in a previous post, government contracts may contain clauses allowing for price increases following the imposition of a new federal tax.  These clauses can also work the other way and require a price decrease (or a credit to the Government under a cost-reimbursement contract) in the event of an after-relieved tax.  Continue Reading Tariff Takedown:  Implications of Tariff Refunds for Government Contractors

On January 23, 2026, the Office of Management and Budget (OMB) issued Memorandum M-26-05 “Adopting a Risk-based Approach to Software and Hardware Security,” which rescinds a previous Biden Administration’s requirement for all federal agencies to obtain a self-attestation from software producers in the “Common Form” developed by the Cybersecurity and Infrastructure Security Agency (CISA) before using certain third-party software.  As its rationale, OMB noted that the prior memoranda diverted agencies from developing tailored assurance requirements and failed to account for threats posed by insecure hardware.  Memorandum M-26-05 signals that the federal government is moving away from a “one-size fits-all” approach to software security and will instead allow each agency to develop tailored requirements.  In creating their own assurance requirements, agencies may still require a self-attestation and/or Software Bill of Materials (SBOM) from the software vendor if the agency determines that such assurances are necessary based on the risks involved and the agency’s needs.Continue Reading OMB Rescinds the “Common Form” Secure Software Attestation Requirement

A 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 Tube

As the federal government focuses on securing reliable supplies of critical minerals, stockpiling has emerged as a key policy tool, alongside direct investments in private enterprises and expanded funding programs for industry.  The National Defense Stockpile (“NDS”) currently serves as the federal strategic reserve of materials needed for national defense, including critical minerals, and the growing policy attention has prompted new proposals and initiatives for upgraded federal stockpiling capabilities.  This blog post reviews the NDS and its activities last year and offers an outlook for critical minerals stockpiling in the year ahead.  Continue Reading Federal Push for Critical Minerals Stockpiling: 2025 in Review and Outlook for 2026  

Among the most challenging areas of regulatory compliance for federal contractors are cost accounting and cost and pricing data disclosure requirements.  Indeed, many companies place guardrails on the nature and scale of their business relationships with the U.S. government precisely to avoid the application of these requirements.  In a move that seems consistent with the federal government’s push towards expanding the defense industrial base and working with more commercial companies, Congress recently released the final negotiated language of the FY 2026 National Defense Authorization Act (“NDAA”).  The draft text, currently awaiting a full Senate vote, contains impactful changes to reduce the applicability of federal Cost Accounting Standards (“CAS”) and the Truthful Cost or Pricing Data Statute (formerly the Truth in Negotiations Act, commonly referred to as “TINA”). Continue Reading FY26 NDAA Aims to Raise the Dollar Thresholds for the Applicability of CAS and TINA

On August 7, 2025, President Trump issued Executive Order 14332, “Improving Oversight of Federal Grantmaking,” (“EO 14332” or “the EO”) to “strengthen oversight and coordination of, and to streamline, agency grantmaking” and “ensure greater accountability for use of public funds.”  Sec. 1.  Among other things, the EO:  (1) directs agencies to review discretionary funding opportunities for consistency with agency priorities; (2) provides principles for agencies to use in assessing discretionary awards; (3) directs the Office of Management and Budget (“OMB”) to revise the Uniform Guidance applicable to federal financial assistance; and (4) requires agencies to include terms and conditions in their discretionary grant agreements allowing for termination for convenience and preventing recipients from drawing down funds without prior written explanation and approval.  Through these methods, EO 14332 focuses on increased political oversight of discretionary funding, ensuring broad termination for convenience rights, and limiting indirect costs.  The EO arrives at the intersection of recent efforts by the Trump Administration both to cancel, terminate, or otherwise pause federal funding viewed as inconsistent with the Administration’s policy priorities and to streamline federal procurement regulations.Continue Reading White House Issues Executive Order Focused on “Improving Oversight of Federal Grantmaking”

The 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

In a recent bid protest decision— Digital Force Technologies, Inc., B-423319 (May 19, 2025), the Government Accountability Office (“GAO”) denied a protest of a Small Business Innovation Research (“SBIR”) program Phase III sole source solicitation issued by the Air Force, concluding that the Air Force had properly procured work from a successor-in-interest entity that derives from, extends, or completes efforts under prior SBIR contracts.  Notably, GAO found that a single SBIR-derived component of the overall system to be procured can be a sufficient link to prior SBIR work for an agency to exercise its authority to issue a sole source SBIR Phase III contract.

This decision builds on previous GAO decisions in ASRC Federal Data Network Technologies, LLC, B-418765, Aug. 28, 2020, 2020 CPD ¶ 339 (“ASRC II”)[1] and Toyon Research Corporation, B-409765, Aug. 5, 2014, 2014 CPD ¶ 235, in which GAO had explained that “it must be evident that the requirements for the second effort incorporated original concepts, findings, ideas, or research results that were generated in the first.”[2] 

This blog post briefly summarizes background on the SBIR program and requirements for Phase III sole source awards, as backdrop to GAO’s findings in Digital Force Technologies.  The post then analyzes particular aspects of GAO’s decision suggesting an expansion of existing case law in this area and concludes with a brief discussion of practical considerations for government contractors.Continue Reading Digital Force Technologies, Inc.:  A “SBIR-Derived Component” Can Be Sufficient For SBIR Phase III

On April 9, 2025, President Trump issued an Executive Order (“EO”), “Modernizing Defense Acquisitions and Spurring Innovation In the Defense Industrial Base,” that may have significant implications for federal government contractors doing business with the Department of Defense (“DoD”), and particularly those with touchpoints to Major Defense Acquisition Programs (“MDAPs”).Continue Reading Trump Administration Issues Executive Order Aimed At Modernizing Defense Acquisitions And Spurring Innovation

President Trump issued a series of executive orders (“EOs”) and presidential memoranda on Wednesday, April 9, that could impact government contractors across a broad range of industries.  Among other initiatives, these executive actions seek to reform the defense acquisition system, reinvigorate the U.S. maritime industry, and streamline foreign military sales.  The actions also reflect President Trump’s goal of catalyzing innovation and economic growth by reducing regulatory burdens, both in general and in the energy industry specifically.

We briefly summarize below the six April 9 executive actions most likely to impact government contractors.Continue Reading New Executive Actions Address the Defense Acquisition System, U.S. Maritime Industries, Foreign Military Sales, and “Unlawful” Regulations