Happy Independence Day from SmallGovCon!

Posted on by

We at SmallGovCon want to wish you and yours a wonderful Independence Day. Be safe this weekend and remember what the day is all about. It is a time to remember what unites as a nation, and consider our shared values and ideals. We hope you have a chance to relax, spend time with family and friends, and enjoy the 4th! We leave you with these words from the Declaration of Independence:

We hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness.

Preamble to the Declaration of Independence

COFC: Limitation on Subcontracting Certification Trips Up Contractor Where Solicitation Requires it to be Signed and Attached

Posted on by

When it comes to federal contracting, there are parts that are very detail-oriented.  Countless signatures for countless certifications. We certainly empathize with contractors on this aspect of federal contracting. But just because we are empathetic does not mean that a contractor can ignore such requirements. In a recent decision, Revelations Counseling & Consulting, LLC v. United States, 180 Fed. Cl. 721 (2026), the Court of Federal Claims (COFC) made it very clear: Where the solicitation says sign the certification and include it in the proposal, sign it and include it in the proposal. Anything less and not only should you expect a rejection, the agency is often required to reject the proposal. In this case, the certification was a VA limitations on subcontracting clause that has cropped up multiple times lately in our practice and is an important part of small business contracting. We look at that decision today.

Continue reading…

SmallGovCon Week in Review: June 22-26, 2026

Posted on by

Happy Friday! With June wrapping up, we’ve officially reached the halfway point of the year. Mid-year is the perfect time for federal government contractors to focus on the goals ahead and prepare for new opportunities in the months to come. Here’s to finishing June strong and carrying that momentum into a productive and successful second half of 2026! We hope you have a wonderful weekend.

This week in federal government contracting news, a good chunk of the Revolutionary FAR Overhaul (aka “FAR 2.0” or the “RFO”) makes its way into formal rulemaking procedures, NASA expands total awards and introduces thousands of new awardees for SEWP (Solutions for Enterprise-Wide Procurement)–NASA’s premier Government-Wide Acquisition Contract, the White House accelerates the governmentwide shift to post-quantum cryptography and stirs up some controversy with a no-bid contract award for its Reflecting Pool renovations, and GAO identifies some anticipated procurement challenges of cloud computing and also, reflects on 2025’s FraudNet Activity Report. But that’s certainly not all. Take a look at this week’s articles for more on these and other happenings in the federal procurement landscape this week.

Continue reading…

Formal Revolution: FAR Council Releases Proposed Formal Rules to Start RFO Rulemaking Process

Posted on by

The FAR Council has released its first batch of proposed rules to amend the Federal Register to implement the changes to the Federal Acquisition Regulation (FAR) to implement the executive order on Restoring Common Sense to Federal Procurement. In this post, we will provide an overview of how the RFO is being implemented as part of the formal rulemaking process. Overall, the proposed regulation seems to follow the vast majority of the proposed language that was already issued under the RFO. We’ve discussed some of those changes in past blog posts. For background, our earlier posts regarding various aspects of the RFO can be found here: Executive Order, Overview of FAR 2.0, FAR Part 6, FAR Part 19 and the Once 8(a) Rule under Part 19, FAR Part 12, FAR Part 15, FAR Part 33, . But this post notes some changes as compared to the original version of the RFO.

Continue reading…

“I Could Have Competed” Won’t Cut It: COFC Requires Showing Contractor Could Perform Work if it Wants to Protest Solicitation Terms 

Posted on by

You have your eye on a solicitation. You know the work, you know the customer, and you are certain that you would be a front-runner for the award. Then, you learn that the agency is limiting competition for the procurement, and you can no longer compete for the contract. Immediately, you think that the agency must have made a mistake. After all, you were fully prepared to submit a proposal and perform the work. But is believing you could have competed for the contract and won the award enough to satisfy the requirements for filing a bid protest? A recent COFC decision answers this question. 

Continue reading…

GovCon FAQs: What Costs Can I Exclude From Limitations on Subcontracting Calculations?

Posted on by

If your small business performs federal government contracts, chances are, you’ve already calculated your small business’s compliance with the applicable limitation on subcontracting (LoS) a time or two. But whether you’re new to the LoS equation–or you’ve long since mastered that math–knowing which costs you can exclude from your calculations is vital. Indeed, such can impact everything from the accuracy of a bidder’s regulatory compliance representations and certifications to a contractor’s critical contract performance and subcontracting decisions. In fact, under current SBA affiliation regulations, LoS compliance can even provide a defense to certain contract-specific findings of affiliation. But calculating LoS compliance and determining exactly which costs to include and exclude on a given contract is not always easy or straightforward. And that’s why we so frequently get this question and break down the answer in this article.

Continue reading…

SmallGovCon Week in Review: June 15-19, 2026

Posted on by

Juneteenth is a day to celebrate freedom, reflect on history, and recognize how far we’ve come as a country. Observed each year on June 19, it marks the day in 1865 when enslaved people in Texas finally learned they were free—more than two years after the Emancipation Proclamation was issued.

Whether you’re attending a local event, spending time with family, or simply taking a moment to learn more about the holiday, we hope you have a wonderful weekend. Happy Juneteenth!

This week in federal contracting news includes stories on the recent DEI order, use of AI in government procurement, and the first look at the upcoming NDAA defense spending bill.

Continue reading…