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?JCIDS, Rewired: What DoD’s New Requirements Memo Means
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
Expired: SBIR/STTR and DPA Authorities in Limbo
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 LimboCybersecurity Maturity Model Certification (CMMC) Program Procurement Final Rule Announced
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 AnnouncedTrump 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 OrdersFraud Prevention in Focus: Examining DOD’s Risk Management Strategies
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
One Big Beautiful Bill Act makes $150B investment in Defense
As part of the One Big Beautiful Bill Act (“OBBBA”) signed into law by the President on July 4th, Congress made approximately $150 billion in appropriations to support defense and national security priorities. As detailed further below, OBBBA touches on many different defense industries and sectors—including the maritime industry, missile systems, space and satellite technologies, nuclear technologies, and artificial intelligence and other advanced technologies. Further, the OBBBA appropriates significant funding to support strategic investments in the defense industrial base and provides the Department of Defense (“DoD”) with an extended timeline (until 2029) to execute these investments. Existing government contractors, and advanced technology providers interested in becoming contractors, should closely monitor the implementation of these OBBBA provisions, which will shape DoD opportunities for years to come.Continue Reading One Big Beautiful Bill Act makes $150B investment in Defense
SPEEDing up Procurement?: House Armed Services Bill Seeks to Reform Defense Acquisition
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
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?
April 2025 Cybersecurity Developments Under the Trump Administration
This is the third blog in a series of Covington blogs on cybersecurity policies, executive orders (“EOs”), and other actions of the new Trump Administration. This blog describes key cybersecurity developments that took place in April 2025.
NIST Publishes Initial Draft of Guidance for High Performance Computing Systems
U.S. National
Continue Reading April 2025 Cybersecurity Developments Under the Trump Administration