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 September 14, 2026, Deputy Secretary of War Stephen Feinberg issued a memorandum and an accompanying appendix focused on strengthening the defense industrial base by reforming acquisition requirements related to a wide range of issues, including accounting standards, efficiency, government oversight, procedural requirements, audits, pricing, and more. Building on prior policymaking, including Executive Order 14402 (April 30, 2026), this memorandum directs agency actions aimed at making defense acquisition more commercially oriented and less dependent on government-unique accounting and oversight regimes.
Among other things, the memorandum directs the Department of War (“DoW”) to shift away from the Cost Accounting Standards (“CAS”) and increase its reliance on the Generally Accepted Accounting Principles (“GAAP”), including by advancing CAS coverage reform at the CAS Board. The memorandum further directs a number of other reforms related to accelerating acquisition transformation, scaling advance market commitments, improving efficiency, reducing administrative burden, limiting audits, streamlining business system reviews, and increasing the use of commercial contracting and other transaction authority (“OTA”) agreements.
Continue Reading Department of War Issues Memorandum Aimed at Strengthening the Industrial Base Through Acquisition ReformOn September 1, 2026, the Cost Accounting Standards (“CAS”) Board published two final rules implementing seismic changes to cost accounting requirements for federal government contractors. The most significant change implements a requirement in last year’s National Defense Authorization Act (“NDAA”), doubling the dollar value threshold for full coverage under CAS.
Continue Reading CAS Board Rolls Out Two Changes with Significant Impact on Federal ContractorsOn 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”On August 11, 2026, the Small Business Administration issued a final rule that fundamentally alters how individuals may qualify as “socially disadvantaged” under the 8(a) Business Development Program. Although the final rule largely follows the proposed rule from June 2026, which we previously wrote about here, the SBA added
Continue Reading SBA Finalizes Changes to the 8(a) Program’s Social Disadvantage RequirementsAs we covered in our previous blog post, the Department of Energy (“DOE”) has launched the “Genesis Mission” to apply AI technology to a wide variety of scientific and technological challenges.
Last week, DOE announced it had selected 278 Genesis Mission projects for potential awards. The selected projects span nuclear energy, quantum computing, advanced manufacturing, and materials science, among other areas. According to DOE, the largest selection is a three-year, $60 million nuclear energy project involving 32 partner entities, including 4 national labs and more than 20 industry partners.
Continue Reading Department of Energy Selects 278 Genesis Mission ProjectsOn May 29, 2026, the Office of Management and Budget (“OMB”), together with several other federal agencies, published a proposed rule that would fundamentally change many aspects of the regulations in 2 CFR Part 200 governing federal financial assistance awards, including grants, cooperative agreements, loans, and loan guarantees. The comment period will be underway until July 13.
The 412 page proposed rule states that it is aimed at increasing transparency, accountability, and oversight in federal financial assistance. It provides examples of “the types of wasteful spending” that it is meant to target, including recipients “potentially misus[ing] funds to provide services for illegal immigrants.”
While the proposed rule contains numerous changes, this post highlights some of the most notable.
Continue Reading Proposed Rule Would Fundamentally Impact Federal Grant and Financial Assistance Framework
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 17, 2026, the Department of Energy (“DOE”) issued a Request for Application (“RFA”) under the Genesis Mission, a White House-led AI initiative announced in November 2025. The RFA, with $293.76 million in anticipated total funding, solicits project proposals for 21 areas ranging from advanced manufacturing and industrial productivity to energy and nuclear physics. Applications for Phase I and letters of intent for Phase II are both due April 28, 2026. This blog post reviews the development of the Genesis Mission since last year and summarizes the key elements of the current funding opportunity.
Continue Reading DOE Announces a New Funding Opportunity under the Genesis MissionOn March 13, 2026, the Department of Energy issued a Notice of Funding Opportunity (NOFO) for projects supporting the development of domestic processing, manufacturing, and recycling capabilities for battery materials. With $500 million in total available funding, the NOFO solicits proposals in three topic areas: (1) domestic critical minerals processing from raw feedstocks, (2) domestic critical minerals recycling, and (3) domestic battery materials and component manufacturing. Letters of intent are due March 27, 2026, and full applications are due April 24, 2026.
Continue Reading DOE Announces Funding Opportunity for Domestic Critical Materials Processing, Recycling, and Manufacturing