AI, Privacy, and the Federal State: Lessons from GAO’s March 2026 Report on Gaps in Government-Wide Guidance
A March 2026 GAO report finds that federal AI guidance still leaves significant privacy gaps. Drawing on expert input, the report identifies major risks such as data re-identification, improper disclosure, and secondary use of data, and concludes that OMB should issue more specific guidance and strengthen interagency information-sharing on AI privacy practices.
Why Federal Government Contractors Need a Different Ethics and Compliance Program
Federal government contractors need ethics and compliance programs that are fundamentally different from commercial-only enterprises. This article explains why procurement rules, mandatory disclosure duties, charging controls, cybersecurity, public-funds stewardship, and contract-specific risks require a more targeted, auditable, and contract-facing compliance framework.
DEI After EO 14173: Where Federal Contractors Stand Now
A practical update for federal contractors on DEI after Executive Order 14173. This article explains the current certification framework, DOJ enforcement posture, False Claims Act risk, procurement changes, and the compliance steps contractors should take now to review programs, document lawful practices, and reduce exposure.
When a Partial Termination Settlement Becomes Final: Lessons from Medical Receivables Solutions, Inc.
This article explains the ASBCA’s decision in Medical Receivables Solutions, Inc., where a contractor’s acceptance of a post-termination payment with broad release language barred any further recovery. The case underscores the legal force of bilateral modifications, releases, and accord and satisfaction in federal contract termination settlements.
When Procurement Decisions Appear Wasteful: A Neutral Framework for Understanding Federal Award Outcomes
An overview of why some federal procurement decisions may appear wasteful, yet still comply with procurement law. Explains the distinction between price alone and best value, the role of technical acceptability and documentation, and how recent GAO decisions illustrate the limits of labeling an award inefficient without a stronger legal basis.
What Industry Often Misses About the Contracting Officer’s Role
A summary of David Neal’s article on what contractors often misunderstand about the contracting officer’s role, including the realities of internal coordination, documentation, protests, RFIs, and the importance of credibility, clarity, and practical communication in federal procurement.
The Justice Department’s Revised Corporate Enforcement Policy and the Strategic Value of Early Disclosure
the Justice Department’s updated Corporate Enforcement and Voluntary Self-Disclosure Policy, explaining how DOJ now structures declinations, cooperation credit, remediation expectations, and intermediate resolution incentives for companies facing potential criminal exposure.
S. 3971 and the Emerging Direction of Federal Innovation Contracting
S. 3971 is not yet law, but its Senate passage signals where Congress may take SBIR and STTR next. The bill would extend the programs through 2031, strengthen research-security screening, expand commercialization pathways, and improve Phase III transition and procurement data tracking.
Ten Lessons from Government Data: Why Public Datasets Demand Humility, Context, and Practitioner Judgment
A summary of Ten Thoughts on Government Data, exploring why public datasets are often incomplete, misleading, and difficult to interpret without practitioner knowledge. The article highlights structural data gaps, sampling limits, bureaucratic incentives, and the need for legal, policy, and operational context when analyzing government information.
Cybersecurity Harmonization and the Regulatory Burden on Critical Infrastructure
A 2026 GAO report finds that overlapping federal cybersecurity regulations are imposing significant burdens on critical infrastructure sectors. While agencies have taken steps toward harmonization, industry participants say duplicative reporting, inconsistent definitions, and fragmented oversight still hinder effective cybersecurity and divert resources from actual risk response.
Buying Blind: Why Federal AI Procurement Needs Stronger Oversight
A 500-word summary of Jessica Tillipman’s article Buying Blind: Corruption Risk and the Erosion of Oversight in Federal AI Procurement, examining how rapid federal AI adoption, weakened oversight, contractor lock-in, opaque systems, and reduced auditability create corruption and integrity risks in public procurement, and why governance is essential to sustainable innovation.
GSA’s Emerging CUI Framework and the Growing Fragmentation of Federal Contractor Cybersecurity Compliance
A summary of Federal News Network’s reporting on GSA’s new CUI protection requirements and the industry concerns they have sparked. The article examines how GSA’s NIST SP 800-171 Rev. 3-based approach differs from DoD’s CMMC framework, why that divergence matters for contractors, and how the absence of a uniform governmentwide standard may increase cost, complexity, and compliance risk.
Offshoring Functional Support Under Federal Government Contracts: Hidden Legal and Compliance Risks
Offshoring functional support under federal contracts can create significant compliance, cybersecurity, trade-agreement, and False Claims Act risk. This article explains why contractors should evaluate offshore performance as a contract-specific legal issue, not merely a cost-saving decision.
Firm-Fixed-Unit-Price Contracts and the FAR Overhaul: A New Acquisition Vehicle with Significant Practical Implications
The FAR Overhaul has surfaced a new contract vehicle: the firm-fixed-unit-price (FFUP) contract. This article explains what FFUP contracts are, how they differ from firm-fixed-price, T&M, and IDIQ arrangements, why they matter for cloud and metered services, and what federal contractors should watch for as agencies begin implementing them through agency procedures and solicitation language.
Managing Foreign Risk in SBIR/STTR Awards: Due Diligence, Disclosures, and What “Phase III” Still Means
SBIR/STTR foreign risk assessments now require enhanced disclosures and agency due diligence under the SBIR/STTR Extension Act of 2022. This article explains NIH’s implementation, ongoing disclosure obligations, the 2025 lapse in SBIR/STTR authority, and why SBIR Phase III awards can still proceed when the work “derives from, extends, or completes” prior efforts.
FOCI and Supply-Chain Disclosure Requirements Are Expanding Across DoD Contracting
DoD’s Section 847-driven FOCI expansion and DCSA’s updated SF-328 signal earlier, broader foreign-ownership and supply-chain scrutiny—potentially at the proposal stage for many unclassified contracts. This shift reshapes diligence, valuation, closing conditions, and post-close governance for government-contracts M&A.
Artificial Intelligence Strategy for the Department of War and the Institutionalization of an AI-First Military
the Department of War’s January 2026 Artificial Intelligence Strategy memorandum, explaining its “AI-first” military doctrine, seven Pace-Setting Projects, governance changes, AI compute and data directives, and the shift from legacy processes to rapid, metrics-driven military AI adoption across warfighting, intelligence, and enterprise missions.
When One CPARS Finding Falls Away
An analysis of Fluor Federal Solutions, LLC (ASBCA No. 61543) and its CPARS implications for federal contractors. The ASBCA distinguished Todd Construction and held that when one major factual basis for an “Unsatisfactory” rating fails, the agency must still prove the remaining record satisfies the contract’s stricter multifactor CPARS standard, leading to remand for reconsideration
Federal Circuit 2025 Decisions on Data Rights and Option Clauses in Federal Contracting
FlightSafety on DFARS commercial technical data legends and “unrestricted rights” in OMIT data, and Beacon Point on FAR option clauses and failed incorporation by reference. The cases highlight clause hierarchy, drafting precision, and risk in data rights and option-year disputes.
Buy, Build, or Hybrid? Why Government LLM Strategy Is a Procurement Issue, Not Just a Technology Choice
Buy versus Build an LLM: A Decision Framework for Governments by Lu, Xu, Tjhi, Li, Bosselut, Koh, and Kankanhalli. This article explains why government LLM decisions involve sovereignty, security, cost, and lifecycle planning—and why federal contractors must adapt by offering secure, auditable, hybrid-ready AI solutions aligned to public-sector procurement priorities.