On February 18, 2026, the General Services Administration (“GSA”) issued a proposed revision to the certifications that federal financial assistance recipients or applicants must make in order to register in the System for Award Management (“SAM”), adding certifications related to diversity, equity, and inclusion programs; immigration; and national security. The proposed revision also addresses applicability in the event of an active injunction. Public comment is due by March 30, 2026.Continue Reading GSA Proposes New SAM Certification Language for Federal Funding Recipients Addressing DEI, Immigration, and National Security
State Department Revives and Expands the Mexico City Policy
On January 23, 2026, Vice President Vance announced the administration’s intent to expand the “Mexico City Policy.” First established by President Reagan, the Mexico City Policy originally prohibited foreign non-governmental organizations (“NGOs”) from using funds to “promote abortion as a method of family planning in other nations.” The policy was repealed by the Biden administration but then reinstated at the outset of the current administration. On January 27, 2026, the State Department implemented the Vice President’s announcement, and expanded the Mexico City Policy to require recipients of “foreign assistance” to abide by award terms reflecting three new policies: (1) Protecting Life in Foreign Assistance (“PLFA”); (2) Combating Gender Ideology in Foreign Assistance (“CGIFA”); and (3) Combating Discriminatory Equity Ideology in Foreign Assistance (“CDEIFA”).[1]
Collectively, the new PLFA, CGIFA, and CDEIFA policies are referred to as the Promoting Human Flourishing in Foreign Assistance policy (“PHFFA”). These rules create new obligations relevant to U.S. NGOs, foreign NGOs, and other international organizations receiving foreign assistance. This blog post focuses on the new CDEIFA requirements—and the potential pitfalls—for U.S. NGOs.Continue Reading State Department Revives and Expands the Mexico City Policy
Overhauling the GSA Schedule
On October 17, 2025, the General Services Administration (“GSA”) announced that it plans to issue a Mass Modification to GSA’s Multiple Award Schedule (“MAS” or “Schedule”) Solicitation[1] and Schedule contracts in November 2025 (“Refresh”). Periodically, GSA may issue a Mass Modification to Schedule contracts to uniformly impose changes to the contract terms applicable to all Schedule contract holders, often as a result of changes in applicable law, regulation, or policy. This approach also ensures that existing Schedule contracts have consistent terms, even though with the evergreen nature of the Solicitation those contracts have been entered into at different times and are at different stages of performance.
This Refresh (i.e., Refresh #30) will implement several significant changes with the goal to align the GSA Schedule with recent developments in the Revolutionary FAR Overhaul (“RFO”).[2] Although the full text of the Refresh is not yet available, GSA’s Refresh outline provides insight into the changes that are to come as GSA seeks to gain implementation experience with the RFO clauses, provisions, and ordering procedures through its Schedule contracts. Given GSA’s leadership of the RFO process, and this year’s Executive Order to consolidate domestic procurement of common goods and services in GSA to the extent permitted by law,[3] it is no surprise that it has acted quickly to revise its long-term government-wide contracting vehicle according to these recent developments.
Along with the Refresh announcement, GSA opened a 10 business day comment window on buy.gsa.gov, which we expect will close on October 31, 2025. Schedules contractors will be expected to accept the Refresh no later than 90 days from its release which is expected sometime in November. Below we discuss relevant background on the RFO process as it relates to the Schedule and anticipated changes to provisions and clauses in the Refresh. We will continue to watch for updates as GSA’s implementation of the RFO unfolds. Continue Reading Overhauling the GSA Schedule
E-Verify and the False Claims Act: An Emerging Tool in Immigration Enforcement
On September 18, 2025, the Department of Justice (“DOJ”) announced a civil False Claims Act (“FCA”) settlement against a New Jersey shipbuilder to resolve allegations that it improperly employed unauthorized workers to work on Navy ships. The settlement, which exceeded $4 million, is the second this year involving government contractors alleged to have employed unauthorized workers in violation of FAR 52.222-54, Employment Eligibility Verification. With immigration enforcement squarely at the center of the current administration’s domestic agenda, government contractors should be mindful of this enforcement theory and take appropriate steps to ensure compliance and protect themselves from a costly FCA claim. Continue Reading E-Verify and the False Claims Act: An Emerging Tool in Immigration Enforcement
Bid Rigging Risk for Government Contractors
Consistent with the Trump Administration’s focus on procurement fraud, a recent settlement and guilty pleas secured by the DOJ demonstrate that bid rigging is in the Administration’s crosshairs. Government contractors should be aware of the legal risks associated with bid rigging when engaging in the bidding process. Continue Reading Bid Rigging Risk for Government Contractors
To Efficiency and Beyond?: President Trump Issues Executive Order to Enable a Competitive Space Launch Market
On August 13, 2025, the White House issued Executive Order 14335, “Enabling Competition in the Commercial Space Industry” (“EO 14335” or the “EO”). Framed as a push to “enhance American greatness by enabling a competitive launch marketplace and substantially increasing commercial space launch cadence and novel space activities by 2030,” EO 14335 directs federal agencies to reform regulatory barriers in four key areas: (1) commercial launch and reentry, (2) spaceport infrastructure, (3) novel space activity authorization, and (4) leadership and accountability. Sec. 2. Each of these initiatives aims to streamline bureaucracy, reduce delays, and accelerate U.S. commercial space growth. Below, we break down the EO’s provisions in each area and examine their significance for industry stakeholders.Continue Reading To Efficiency and Beyond?: President Trump Issues Executive Order to Enable a Competitive Space Launch Market
White House Issues Executive Order Focused on “Improving Oversight of Federal Grantmaking”
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”
Trump Administration Issues AI Action Plan and Series of AI Executive Orders
On July 23, the White House released its AI Action Plan, outlining the key priorities of the Trump Administration’s AI policy agenda. In parallel, President Trump signed three AI executive orders directing the Executive Branch to implement the AI Action Plan’s policies on “Preventing Woke AI in
Continue Reading Trump Administration Issues AI Action Plan and Series of AI Executive OrdersContinued Signs of Progress in the Revolutionary FAR Overhaul
Since President Trump issued Executive Order (“E.O.”) 14275, “Restoring Common Sense to Federal Procurement” on April 15, 2025 as part of an effort to remake Federal procurement, the Administration has undertaken a variety of initial steps to implement its so-called “Revolutionary FAR Overhaul” (“RFO”). These steps include “streamlining” each Part of the Federal Acquisition Regulation (“FAR”) on a rolling basis to remove “non-statutory requirements.” To date, seven streamlined FAR Parts have been released on the RFO page of acquisition.gov: Parts 1, Federal Acquisition Regulation; 10, Market Research; 11, Describing Agency Needs; 18, Emergency Acquisitions; 34, Major System Acquisition; 39, Acquisition of Information and Communication Technology; and 43, Contract Modifications. The public has the opportunity to provide “informal input” for each Part—the soonest of which is to provide feedback on FAR Part 10 by July 7, 2025 at 4:30 PM ET.[1] Although the volume of streamlined FAR Parts, non-regulatory resources, and commentary on acquisition.gov has started to proliferate in recent weeks, the extent to which these resources can and will be relied on in a strategic, accessible manner by the broader acquisition community still remains to be seen. Continue Reading Continued Signs of Progress in the Revolutionary FAR Overhaul
GAO: DCAA Built a Valuable Bench of Independent Public Accountants, Now What?
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?