Department of Defense class deviations are implementing the Revolutionary FAR Overhaul across multiple FAR and DFARS parts, with effective dates beginning as early as February 1, 2026. These changes affect clause structure, regulatory language, and timing considerations, requiring contractors to closely evaluate solicitations, flowdowns, and contract terms to maintain alignment with updated requirements.

Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)

Government contractors will see another significant change to the acquisition threshold under the FY 2026 National Defense Authorization Act. The Truthful Cost or Pricing Data threshold is increasing to $10 million, creating new considerations for proposals, negotiations, and contract modifications. Multiple threshold updates within a short period have introduced added complexity around timing, clause language, and award dates. Understanding how these changes interact with existing contracts is essential for maintaining consistency and avoiding unnecessary compliance risk.

Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Estimating System Compliance

In reference to the now outdated terminology “Multiple Personality Disorders” (now “DID” or Dissociative Identity Disorder), my focus is on two Government actions, the 2026 NDAA (National Defense Authorization Act) and the very recent EO (Executive Order), “Prioritizing the Warfighter in Defense Contracting.” Before getting into the substance of this blog, just to note that one can only hope that the proposed/legislated changes to improve the efficiencies and effectiveness of the procurement process (for the Department of War and more broadly the US Government) will actually succeed and not be just one more set of idealized and unfulfilled political promises.

Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)

Recent statutory changes under the FY 2026 National Defense Authorization Act revise the applicability thresholds for the Cost Accounting Standards and limit certain post-award contract price adjustments. These updates affect how contractors evaluate fixed-price awards, accounting practice changes, and clause timing, as regulatory implementation is expected within 180 days of enactment.

Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)

On December 5, 2025, the Department of Justice (DOJ) reported another settlement under the False Claims Act (FCA) related to cybersecurity. Swiss Automation agreed to pay $421,234 to the Government as a result of failing to provide adequate cybersecurity controls for drawings of parts supplied to Department of Defense (DoD) prime contractors. The qui tam suit under the False Claims Act (FCA) was brought forward by a whistleblower, not an Information Technology (IT) employee, but a Quality Control Manager of the company. The whistleblower received $65,291.

Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Cybersecurity, Commercial Item Determination

On Sunday, December 7, 2025, Congress put out a compromise version of the 2026 National Defense Authorization Act (NDAA). There is a lot in this version, but I wanted to bring to your attention the exciting possible changes to the Cost Accounting Standards (CAS).

Topics: Accounting System Compliance, Contracts & Subcontracts Administration, Government Regulations, Export & Import, Cost Accounting Standards (CAS)

EO 14173 revoked EO 11246 Equal Employment Opportunity, which required covered federal contractors to practice affirmative action, develop written Affirmative Action Plans (AAPs) and implement compliant programs directed towards equal opportunities for women and minorities. This major change left contractors with a choice: set aside all efforts previously made toward compliance with EO 11246, or continue with employment analytics under a framework acceptable under EO 14173. In this article, we explain why we encourage you to consider the continuation of these efforts.

Topics: Contracts & Subcontracts Administration, Human Resources, Government Regulations, Office of Federal Contract Compliance Programs, Service Contract Act

Well, our friendly DCAA auditors are back after the Government shutdown. On December 2, 2025, Defense Contract Audit Agency (DCAA) issued a memorandum to their auditors titled, “Actions Required for Assignment Due Dates Following Furloughs.”

Topics: Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations

The Department of Defense (DoD) issued a final rule on September 10, 2025, amending the Defense Federal Acquisition Regulation Supplement (DFARS) to incorporate the requirements of the Cybersecurity Maturity Model Certification (CMMC) for FAR-based contracts and subcontracts, effective November 10, 2025.

Topics: Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR), Cybersecurity, Grants & Cooperative Agreements (2 CFR 200)

The January 2025 EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, triggered mixed emotions amongst HR professionals in the GovCon community – shock, disappointment, and celebration, to name a few. While all might not agree with the requirements of EO 14173, most likely agree that it has caused a great deal of confusion and uncertainty about what is expected, or, more importantly, what is no longer allowed of government contractors. In a previous article released shortly after the EO was signed, we outlined the crux of the EO and overarching implications. As time has passed and more information has come to light, including Attorney General Bondi’s July 2025 memo for federal agencies, we are gleaning additional insights to share.

Topics: Small Business Compliance, Contracts & Subcontracts Administration, Human Resources, Government Regulations, Office of Federal Contract Compliance Programs, Service Contract Act