GSA Quietly Raises the Cybersecurity Bar for Contractors Handling CUI
On January 5, 2026, the General Services Administration (“GSA”) issued CIO-IT Security-21-112 Revision 1, a procedural guide establishing new requirements for protecting Controlled Unclassified Information (“CUI”) in nonfederal contractor systems. While not promulgated as a FAR rule, the guide establishes a mandatory approval framework that contracting officers may apply immediately to new contracts involving...
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Use AI to support your work—not to replace your professional judgment
As Artificial Intelligence tools (such as ChatGPT, Harvey, CoPilot, Claude, etc.) become more accessible, many attorneys have begun exploring how to best use AI tools in their practices. While such tools can streamline workflows, there are many recent examples showing that AI is not a substitute for professional judgment and its misuse carries real...
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SBA Issues Suspension Notices to 8(a) Participants That Failed to Timely Respond to Data Call With Complete Responses: What 8(a) Participants Need to Know
SBA Acts Quickly and Issues Suspension Notices On January 21, 2026, just two days after the deadline for all 8(a) Participants to respond to a comprehensive audit (often referred to as the “8(a) Data Call”), the SBA issued Notices of Suspension to 8(a) firms for apparent failure to submit all required documentation in response...
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Protests Based on Impaired Objectivity Organizational Conflict of Interests (“OCI”) Continue to Find Success at GAO
In Solutions71, LLC: B-423671.2, GAO sustained the third impaired objectivity OCI protest within the last six months. GAO’s decision in Solutions71 joins Castro & Company, LLC: B- 423689 and DirectViz Solutions, LLC:B- 423366; B-423366.3; B-423366.4 in what has become an increasingly successful protest ground. What is an Impaired Objectivity OCI? An impaired objectivity OCI...
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Two CAS Moves in One Day: What Small Contractors Need to Know
On September 11, 2025, the Office of Management & Budget’s (“OMB”) Cost Accounting Standards Board, which is chaired by the Office of Federal Procurement Policy (“OFPP”), dropped two important updates: A final rule that simplifies how revenue and leases are handled under CAS; and A proposed rule that would scale back or align four...
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Federal Circuit, Sitting En Banc, Reverses Landmark Panel Decision on Bid Protest Standing
Back in June 2024, we wrote about a 3-judge panel’s holding in Percipient.AI, Inc. v. United States, 104 F.4th 839 (Fed. Cir. 2024), that a contractor was permitted to bring a bid protest against the government alleging violations of a procurement statute even though it did not “challenge a contract, proposed contract, or solicitation...
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