DoD

On March 3, 2026, the Senate took a major step toward reauthorizing the Small Business Innovation Research/Small Business Technology Transfer (“SBIR/STTR”) programs, by passing the Small Business Innovation and Economic Security Act (S. 3971).  Known collectively as “America’s Seed Fund,” the SBIR and STTR programs provide small businesses with early-stage…

Continue Reading Is Congress Finally Reauthorizing SBIR/STTR—and What’s Changing?

The past month has marked a series of announcements from the Department of War (the “Department”) emphasizing rapid deployment of artificial intelligence (“AI”) industry partnerships.  These announcements signal opportunities for not only the defense industrial base, but also nontraditional defense contractors focused on technology and data.

On January 9, 2026, the Department released two key memoranda: (1) Artificial Intelligence Strategy for the Department of War, setting out measurable pace-setting projects, barrier removal authorities, and mandated data access; and (2) Transforming the Defense Innovation Ecosystem to Accelerate Warfighting Advantage, which aims to unify the defense innovation ecosystem under the Under Secretary of War for Research & Engineering as Chief Technology Officer (“CTO”).  

Shortly after, on January 12, Secretary Hegseth delivered a speech, presenting an overhaul of the Department’s innovation and acquisition ecosystems.

The January 9 memoranda and Secretary Hegseth’s speech signal the Department’s intent to formalize a single, CTO-led innovation operating system designed to produce three outputs: next-generation technology, scalable products, and new ways of fighting—and to do it at “wartime speed,” with AI as the first major proving ground.Continue Reading Pentagon Releases Artificial Intelligence Strategy

Massachusetts aims to be the “cornerstone of the defense industry,” with Governor Maura Healey announcing nearly $47 million in government funding for defense-related projects.  Last year, the Department of Defense ranked Massachusetts ninth out of the top ten states in total Defense spending in FY2023, and the state is aiming…

Continue Reading Massachusetts Seeks to Expand Defense Footprint with Nearly $47 Million in New Projects

This is the seventh blog in a series of Covington blogs on cybersecurity policies, executive orders (“EOs”), and other actions of the Trump Administration.  The sixth blog is available here and our initial blog is available here.  This blog describes key cybersecurity developments that took place in August, September…

Continue Reading August, September, and October 2025 Cybersecurity Developments Under the Trump Administration

Now that the final Cybersecurity Maturity Model Certification (CMMC) Program and Procurement Rules have been issued by the Department of War (DoW) (see our CMMC Toolkit for in-depth analysis of these Rules) and the CMMC Program is set to begin in earnest, there is some uncertainty in industry as to…

Continue Reading How Will DoW Determine Which Level of CMMC Applies to My Agreement?

On August 20, 2025, the Department of Defense (“DoD”) issued a sweeping memo that tears up and rebuilds the way the military decides what new weapons and systems it needs.  The Military Services appear to be wasting no time translating the memo into action.  Acquisition leaders at last week’s Association of the United States Army conference emphasized that “Transforming in Contact” will serve as the framework for redefining requirements and reprioritizing programs—demonstrating that reform is already underway.  For its part, the Air Force has begun reorganizing its A5/7 directorate to assume greater responsibility for requirements generation, while the Chief of Space Operations has publicly outlined the Space Force path to driving requirements and resourcing.  

This “requirements process” is the first step in acquisition—it defines the problem and tells the rest of the system what to buy, build, or develop.  Change the requirements process and you change the entire defense marketplace.  For decades, DoD has used a system called the Joint Capabilities Integration and Development System (“JCIDS”).  JCIDS was paperwork-heavy and checklist-driven:  the Military Services (Army, Navy, Air Force, Marine Corps, Space Force) would write lengthy justifications for new programs, and those proposals would wind their way through layers of approval at the Joint Staff in the Pentagon.  Critics said JCIDS was too slow and too rigid for modern threats, especially as China and other adversaries innovate quickly.

The August 20 memo blows up that model.  In its place, DoD is putting forward a problem-focused approach that aims to:

  • Define the biggest operational challenges first(not just collect Military Service wish lists)
  • Tie priorities to moneyso “important” projects actually get funded
  • Bring industry into the process earlierthrough experiments, not just proposals
  • Cut out layers of low value review

Below we unpack the memo and offer five practical takeaways for industry.Continue Reading JCIDS, Rewired:  What DoD’s New Requirements Memo Means

Two cornerstone authorities for federal contracting quietly expired on September 30, 2025, creating ripple effects that contractors—small and large—cannot afford to overlook.  The Small Business Innovation Research/Small Business Technology Transfer (“SBIR/STTR”) programs, commonly known as “America’s Seed Fund” for their role in fueling early-stage innovation, and the Defense Production Act…

Continue Reading Expired:  SBIR/STTR and DPA Authorities in Limbo

This blog post discusses the Department of Defense’s (“DoD”) new cybersecurity rule that imposes certain cybersecurity requirements on relevant DoD contractors and subcontractors. The post will be of interest to all DoD contractors, subcontractors, and possibly affiliates of contractors that may be impacted by the new rule’s cybersecurity requirements.

On…

Continue Reading Cybersecurity Maturity Model Certification (CMMC) Program Procurement Final Rule Announced

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 Orders

The Department of Defense (“DOD”) is responsible for almost half of the federal government’s discretionary spending and spends more on contracting than all other federal agencies combined, obligating about $445 billion in fiscal year 2024. Given the renewed focus on fraud detection and prevention across the U.S. government – as highlighted both by the efforts of the Department of Government Efficiency (“DOGE”) and by recent congressional committee hearings focused on reducing waste, fraud, and abuse – the issue of fraud in DOD has become increasingly relevant.

On June 4, 2025, the House Committee on Oversight and Government Reform’s Subcommittee on Government Operations held a hearing titled “Safeguarding Procurement: Examining Fraud Risk Management in the Department of Defense,” during which congressional members examined strategies to combat fraud in DOD – including procurement fraud – and the steps the department is taking to address the problem.Continue Reading Fraud Prevention in Focus: Examining DOD’s Risk Management Strategies