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Friday Flash 06/06/2025

June 5, 2025

Why You Don’t Want to Miss the Spring Training Conference!

As the federal marketplace continues to evolve under the new Administration, the Coalition’s 2025 Spring Training Conference is your opportunity to stay informed and engaged on the latest acquisition initiatives shaping government procurement. Taking place in less than three weeks on June 25-26 at the Fairview Park Marriott in Falls Church, Virginia, this two-day event is quickly approaching! Now is the time to secure your spot and ensure you are part of the conversation shaping the future of federal acquisition.

Below are just a few of the major developments in procurement that government and industry leaders will address.

GSA Vision for Future of Federal Procurement

We are thrilled to kick off the Spring Training Conference with keynote remarks from Federal Acquisition Service (FAS) Commissioner Josh Gruenbaum on The New Federal Market and Delivering Best Value. FAS, under the leadership of Commissioner Gruenbaum, is consolidating domestic, government-wide procurement to streamline processes and create efficiencies. Commissioner Gruenbaum will touch on FAS’ operational processes to ingest procurement from around the government, and how these efforts will help FAS provide greater mission support for agencies. In addition, he will discuss GSA’s efforts to rightsize the Multiple Award Schedule Program, as well as its new OneGov initiative.

Procurement Consolidation Executive Order

A March Executive Order (EO), Eliminating Waste and Saving Taxpayer Dollars by Consolidating Procurement, directs agencies to consolidate overlapping contracts and reduce procurement redundancies across government. The goal of the EO is to eliminate waste, improve efficiency, and save taxpayer dollars. The New FAS in the New Federal Market: Procurement Consolidation Panel, which features General Services Administration (GSA) Senior Procurement Executive Jeff Koses and Kristen Wilson, Acting Associate Administrator of the Office of Federal Procurement Policy (OFPP), will explore the implications of this order and how it impacts agency operations.

Revolutionary FAR Overhaul

The Federal Acquisition Regulatory (FAR) Council has launched the Revolutionizing Federal Acquisition Regulation (RFO) initiative to conduct the most comprehensive overhaul of the FAR in decades. This effort aims to streamline and modernize the FAR to better reflect current market conditions, promote innovation, and reduce unnecessary complexity and duplication. The Procurement Policy and the New Federal Market Panel, featuring Larry Allen, GSA Associate Administrator, Office of Government-wide Policy, and Rob Burton, Crowell & Moring Partner, will dive into the scope of the rewrite and what it means for contractors and the acquisition workforce.

Commercial Solutions Executive Order

An April EO, Ensuring Commercial, Cost-Effective Solutions in Federal Contracts, directs agencies to prioritize commercial, cost-effective solutions and eliminate unnecessary barriers to entry. The EO emphasizes the Federal Government’s obligation to leverage the competitive marketplace and private-sector innovation to deliver more efficient goods and services to taxpayers. The New Federal Market: Acquisition Policy Reform Panel will explore how this EO is being implemented across agencies and the implications for industry. Panelists include:

  • John Tenaglia, Principal Director, Defense Pricing, Contracting and Acquisition Policy
  • Mathew Blum, OFPP, Office of Management and Budget (invited)
  • Moshe Schwartz, President, Etherton and Associates
  • Bill Greenwalt, Senior Fellow, American Enterprise Institute

GSA OneGov Initiative

GSA recently unveiled its OneGov strategy to modernize how the Federal Government purchases goods and services. By improving how agencies acquire and deliver mission support services, OneGov aims to reduce costs, boost efficiencies in acquisition, and improve customer experience across the government. The New Federal Market: OneGov Panel will explore the strategy’s implications for acquisition professionals and how it supports broader efforts to streamline government operations. Panelists include:

  • Jeff Lau, Assistant Commissioner, Office of General Supplies and Services, GSA
  • Christina Kingsland, Acting Assistant Commissioner, Office of Travel, Transportation and Logistics, GSA
  • Pete Burr, Acting Assistant Commissioner, Office of Assisted Acquisition Services, GSA
  • Greg Rollins, Deputy Assistant Commissioner, Office of Policy and Compliance, GSA
  • Larry Hale, Deputy Assistant Commissioner, Office of Information Technology Category, GSA
  • Adam Soderholm, Director, Center for Professional Services, Office of Professional Services and Human Capital Categories, GSA

Cybersecurity and DoD Acquisition: CMMC & SWFT

The Department of Defense (DoD) is advancing two critical efforts to improve cybersecurity and modernize software acquisition. The Cybersecurity Maturity Model Certification (CMMC) program continues to evolve and looks to reinforce supply chain security requirements for contractors. In addition, DoD has launched the Software Fast Track (SWFT) initiative to accelerate how secure software is acquired, tested, and authorized across the department. We’re honored to welcome Leslie Beavers, Principal Deputy Chief Information Officer at DoD, as the Luncheon Keynote Speaker to discuss these and other DoD initiativesin the new federal market.

VA Acquisition Operations

The Department of Veterans Affairs (VA) is conducting a comprehensive review of its acquisition operations to better serve veterans and improve internal efficiency. This review includes an assessment of procurement structures, contract management, and vendor engagement practices. We have invited executive from the VA to participate on The New VA Office of Acquisition, Logistics, & Construction to examine the review’s early findings and its potential impact on VA contracting moving forward.

Pricing, Policy and Compliance Developments in Healthcare

A newly released EO, Delivering Most-Favored-Nation Prescription Drug Pricing to American Patients, directs federal agencies to pursue most-favored-nation pricing for prescription drugs. Our Healthcare Legal Panel will address this policy as it relates to contractors, as well as other recent policies impacting the federal healthcare market. Panelists include:

  • Kristin Hicks, Partner, Arnold & Porter
  • James Kim, Shareholder, Polsinelli
  • Stephen Ruscus, Partner, BakerHostetler
  • Jennifer Plitsch, Partner, Covington & Burling


These are just a few of the important topics that will be discussed at the Spring Training Conference. Join us June 25-26 to hear directly from policymakers and industry leaders about the road ahead for federal acquisition!

Explore the full governmentwide agenda here.

Explore the full healthcare agenda here. 

To register, click here. For questions or assistance with registration, please contact Madyson Whiting at mady.whiting@thecgp.org

The hotel block at the Fairview Park Marriott has been extended to June 13, but space is very limited. Reserve your room as soon as possible to ensure you don’t miss out!Book your group rate at the Fairview Park Marriott here. The Coalition is currently working to secure additional rooms at the nearby Residents Inn Marriott. Please standby for additional updates next week.

Thank You to our Spring Training Conference Sponsors!

Sponsorship opportunities still remain, but the deadline is quickly approaching! The final day to commit to a sponsorship and have your company highlighted in on-site conference materials is June 10! Don’t miss the opportunity to showcase your organization’s brand in front of Federal procurement leaders and connect with industry colleagues.

View the Sponsorship Prospectus here. If you have any questions, or are ready to secure your sponsorship, please contact Heather Tarpley at htarpley@thecgp.org.

Join the Conversation: Spring Training Conference Social Media Kit Now Available! 

As we count down to the 2025 Spring Training Conference on June 25 – 26, we are excited to launch our official Social Media Kit to help you spread the word about the event! Whether you’re attending or sponsoring, you can now download customizable graphics and sample social media posts to share your involvement in the Conference. 

Let your network know you will be joining the conversation on “What’s Next for the Federal Market” with the hashtag #CGPSpring2025.  

Follow the Coalition on LinkedIn, Facebook, and X for the latest Conference updates and highlights.  

Download the kit here and help us build momentum as the conference approaches!  

GSA Leadership on the “Vision Behind the FAR Overhaul” 

The General Services Administration (GSA) published a new blog this week on GSA’s Revolutionary Far Overhaul (RFO) initiative co-authored by GSA Acting Administrator Stephen Ehikian and Federal Acquisition Service (FAS) Commissioner Josh Gruenbaum. The blog is the first in a two-part series on this topic. Read the full blog below: 

The Revolutionary FAR Overhaul (RFO): A Metaphor 
Imagine you’ve lived in a large apartment building that was originally designed to be simple and functional. Over the years, new wings were added, staircases rerouted, and hallways extended. Each change responded to a specific need at the time—an extra room here, a safety requirement there, a rule to address a unique situation. But decades later, the result is a confusing maze. Residents, especially the new ones, need a map just to get from their door to the laundry room. 

Long-time tenants know the quirks, but even they agree it’s not easy to live in. 

Now imagine the building’s original blueprint is being rediscovered—not to go backward, but to return to what was essential. A team of architects is proposing a full renovation. They’ll keep the structural elements required by law—the foundation, the support beams—but strip away the patchwork of additions. In their place, they’ll create open, usable spaces designed for how people actually live and work today. Instead of rules taped to every wall, residents will get a practical living guide. It will be easy to follow and separate from the structure itself. 

This is where we find ourselves with the Federal Acquisition Regulation. For the first time, the FAR is being comprehensively overhauled. It is being pared back to its statutory foundation and rewritten in plain language. Many of the one-off rules and procedural add-ons will move out of the regulation and into flexible, practical guides. The goal is a clearer, more navigable FAR—a FAR that supports smart buying, fosters innovation, and keeps us grounded in law without being boxed in by decades of complexity. 

The Opportunity Before Us 
This transformation isn’t about abandoning rules or throwing caution to the wind. It’s about finding a better balance between compliance and effectiveness. 

We need to: 

Trust our training and expertise: Most acquisition professionals have developed sound judgment through years of experience. That knowledge doesn’t disappear when guidance is reduced. 

Focus on principles rather than procedures: Instead of following step-by-step instructions, we’ll need to internalize the core principles of fair, efficient, and effective procurement. 

Collaborate more: When the path isn’t explicitly marked, we’ll need to consult with colleagues, share experiences, and build collective wisdom. 

Accept that mistakes will happen: What matters is how we learn from them. 

The Inevitable Adjustment Period 
Let’s be honest—there will be an adjustment period, and it might be uncomfortable. 

This discomfort is normal. In fact, it’s a necessary part of growth. Remember learning to ride a bicycle? The wobbly phase was frustrating but essential to eventually riding with confidence. 

GSA Expands Contracts Review to Value Added Resellers 

Washington Technology reports that as part of GSA’s OneGov initiative to streamline Federal procurement, the agency is requesting detailed contract and pricing data from ten major information technology (IT) value-added resellers. The companies have been requested to submit information by June 11 detailing contract terms, agency customers, service categories, original equipment manufacturer (OEM) costs, markups, and additional fees. The move expands GSA’s contract review efforts, which began earlier this year with consulting firms, and reflects a broader push to centralize IT purchasing and reduce costs across the Federal Government. According to the article, GSA plans to use the information to help create a scorecard to potentially establish a cap on markups or other cost controls pertaining to OEMs and vendors. 

Opportunity for Industry Input on FAR Rewrite

NextGov reports that while the Federal Government is not actively responding to industry comments regarding the rewrite of the Federal Acquisition Regulation (FAR), acquisition executives are regularly monitoring the feedback. The effort, which is led by the Office of Federal Procurement Policy (OFPP) and the FAR Council, aims to shrink the FAR to include “provisions required by law or essential to sound procurement.” So far, class deviations have been issued for FAR Parts 1, 10, 34, and 52. The changes can be tracked on the RFO website, which also allows industry to provide feedback.     

“We’re not going to formally respond to the feedback in this stage. We’re reading it. We’re having conversations that may influence some of the other material, and it will certainly influence us when we move to the rulemaking stage,” said GSA Senior Procurement Executive Jeff Koses during a townhall meeting last week. “Each FAR part (change) will have a 45 day-feedback period as the standard.” Koses added that the rewrite is “going to move fast” and “through a series of deviations.” 

Join the FAR Rewrite Working Group   

The Coalition is establishing a FAR Rewrite Working Group to provide written comments on the changes to the FAR made by the FAR Council and the Office of Management and Budget (as described in the above article). We are seeking volunteers who will work with the Coalition staff to review the FAR Parts posted on the new Revolutionary FAR Overhaul website and draft comments to submit to the government. Our comments will be submitted on a rolling basis through September 30, 2025. To join the FAR Rewrite Working Group, please contact Greg Waldron at gwaldron@thecgp.org.   

DoD Issues Guidance on Implementing EO 14271 to Promote Commercial Solutions

On May 30, the Department of Defense (DoD) issued guidance implementing Executive Order 14271, Ensuring Commercial, Cost-Effective Solutions in Federal Contracts. The Defense Pricing, Contracting, and Acquisition Policy (DPCAP) memo outlines immediate and future requirements to limit the use of non-commercial solutions in DoD prime contracts. The guidance requires the following actions:

  • By June 15, 2025, Senior Procurement Executives must direct contracting officers to review all pending FAR actions for non-commercial products or services valued at or above the Simplified Acquisition Threshold.
  • Contracting officers must consolidate or create an application for each relevant notice or award, justifying the use of a non-commercial solution and requesting concurrence to proceed.
  • Applications must include statutory justifications and a clear rationale for pursuing government-unique or custom-developed solutions.
  • Agencies must establish internal review processes for non-commercial procurements and submit an annual report to DPCAP, with the first due by July 25, 2025.

White House Budget Request Includes $45 Million in Additional DOGE Funding  

NextGov reports that the President’s budget request includes $45 million and 150 staffers for the Department of Government Efficiency (DOGE). The request includes $10 million for a “software modernization initiative,” while the remaining $35 million will come from agencies reimbursing DOGE for services. DOGE is also expected to have $22 million left in savings from this year. DOGE currently reports $175 billion in savings. However, this total is heavily disputed. The DOGE Service Temporary Organization, which was established to advance the President’s 18-month DOGE agenda, is expected to sunset on July 4, 2026. 

Budget Request Cuts CISA Staff at DHS 

Federal News Network reports that the latest version of the President’s budget request proposes cutting more than 1,000 positions from the Cybersecurity and Infrastructure Security Agency (CISA). The cuts are spread across CISA’s various divisions including cybersecurity, infrastructure security, mission support, integrated operations, and emergency communications.  

The most significant cuts would impact the risk management operations division and stakeholder engagement and requirements division. Cuts related to election security represent about $40 million, and CISA’s stakeholder engagement program would lose about $55 million in funding. In addition, the National Risk Management Center’s budget would be reduced by about $70 million. The budget proposal also eliminates the Chemical Security Anti-Terrorism Standards program which is no longer authorized by Congress. 

White House Proposes New TMF Funding Model 

Fedscoop reports the President’s new proposed funding model for the Technology Modernization Fund (TMF) for fiscal year 2026 would bypass Congress by allowing GSA to collect unused, expired discretionary funds from Federal agencies of up to $100 million annually. This new model is based on provisions in the 2024 Further Consolidated Appropriations Act. It would replace the traditional method of seeking new appropriations to fund Federal IT modernization efforts.  

GSA reports high agency demand for TMF services, having received over 290 proposals requesting $4.5 billion. In its FY 2026 Congressional Justification, GSA stated that this model “is essential to providing the TMF with the necessary funds to help the Federal Government address critical technology challenges by modernizing high-priority systems, improving AI adoption, and supporting cross-Government collaboration and scalable services.” 

FedRAMP 20x Phase 1 Pilot Authorizations Begin 

Last Friday, FedRAMP updated its webpage with information about the FedRAMP 20x Phase One pilot, referred to as FedRAMP 20xP1, to reflect the start of authorizations through the pilot program. The new webpage includes “requirements, how to submit, what to submit, and what to expect” from the FedRAMP 20xP1 pilot. The pilot program uses Key Security Indicators (KSIs) and machine-readable data to automate the assessment and validation of a cloud service’s security capabilities.  

Those who complete phase one will “receive a 12-month FedRAMP Low program authorization and will be prioritized for FedRAMP Moderate program authorization in Phase Two.” 

OASIS+ Program Update 

GSA’s Office of Professional Services and Human Capital Categories published an update on its OASIS+ program, including resources to assist Federal customers and contractors with contract utilization and answers to frequently asked questions. Important updates include: 

  • The OASIS+ Website has been migrated to a new interface on GSA.gov at gsa.gov/oasis-plus. The site provides resources and information about the contract.  
  • The OASIS+ contractor list is available on the Buyers’ Guide page and Sellers’ Guide page of the website in the ‘announcements’ box at the top. 
  • GSA has started market research to explore adding additional domains to the OASIS+ contracts. GSA is in the planning and strategy development stages for reopening the solicitations to accommodate the addition of new domains and will provide more specific information when it is available. 
  • OASIS+ Sales Reporting Portal (SRP) training video for contractors is available via a link at the bottom of the OASIS+ website’s Reporting page. 

VA’s T4NG2 Faces Protests as Court Sets Timeline 

Washington Technology reports that last week, a Federal judge accepted the Department of Veterans Affairs’ (VA) corrective plan for its T4NG2 IT services contract vehicle, adding three companies to the list of prime contractors. Twenty-six protests remain open at the Court of Federal Claims (COFC). After accepting the VA’s plan, the COFC judge stated that the companies may keep their protests open but must file amended complaints by July 14. The VA has agreed to not begin awarding task orders for T4NG2 until March 2026 to allow time for the protests to go through the court process.  

The judge has approved a schedule proposed by the VA that sets deadlines for filings from both the VA and the protesters, including motions and cross-motions, with oral arguments scheduled for February 2026. If T4NG2 launches in March 2026, it will mark nearly two-and-a-half years since the VA initially made awards in October 2023. March 2026 is also the anticipated expiration of the current T4NG contract.

Save the Date: 2025 Joseph P. Caggiano Memorial Golf Tournament, August 20 

The Coalition is pleased to announce that registration is now open for the 12th annual Joseph P. Caggiano Memorial Golf Tournament, which will take place on Wednesday August 20, 2025 at the beautiful Whiskey Creek Golf Club in Ijamsville, Maryland. This much-anticipated event brings together golfers of all skill levels for a day of friendly competition, networking, and most importantly, giving back. The tournament is held each year in honor of our dear friend and colleague, Joe Caggiano. Joe served eight years as an officer in the United States Navy. To honor Joe’s legacy, proceeds from the tournament support two charitable causes dedicated to the brave men and women who have served our country. 

To register for the Joseph P. Caggiano Memorial Golf Tournament, click here.

Paws for Purple Hearts 

Proceeds from this year’s golf tournament will once again support Paws for Purple Hearts! Paws for Purple Hearts improves the lives of veterans and wounded service members facing mobility challenges and trauma-related conditions through assistance dogs and canine-assisted therapeutic programs. In addition, Paws for Purple Hearts builds public awareness about the important role dogs play in helping veterans and service members on the road to recovery. Thanks to the outstanding generosity of our sponsors and members, we have raised over $20,000 for this wonderful organization.  

Learn more about Paws for Purple Hearts in this interview with the Coalition! 

The Coalition for Government Procurement Endowed Scholarship Fund 

In addition, the tournament supports The Coalition for Government Procurement Endowed Scholarship Fund at The George Washington University Law School. This fund assists qualified veterans pursuing graduate studies in U.S. government procurement, helping them build careers in federal acquisition and continue their service to the nation in a new way. We have been fortunate to raise over $140,000 for this fund due to our members and sponsors.  

Whether you’re a seasoned golfer, beginner, or just want to enjoy the stunning views of Whiskey Creek, we invite you to join us for this special day of camaraderie, competition and commitment to service. 

Sponsorships Now Open for the Annual Golf Tournament – Featuring New Opportunities!

We’re excited to announce that sponsorship opportunities are now open for one of the Coalition’s most anticipated events of the year – the Joseph P. Caggiano Memorial Golf Tournament, taking place on August 20 at Whiskey Creek Golf Club in Ijamsville, Maryland. From brand-new options like Golf Ball and Golf Towel Sponsors, to returning favorites like Hole and Beverage Cart Sponsors, there’s a great variety of options to choose from!

Each year, this unforgettable day brings together members, colleagues, and friends for a memorable mix of competition, camaraderie, and community impact. Proceeds from the tournament benefit Paws for Purple Hearts and The Coalition’s Endowed Scholarship Fund at The George Washington University Law School, continuing Joe Caggiano’s legacy of service and support for veterans.

We’re proud to offer a variety of sponsorship opportunities to fit every business and budget. Many of our sponsorships include golfer registrations as well, a benefit that allows you to support two outstanding veteran-focused causes, promote your company to the federal procurement community, and enjoy a round of golf at one of the area’s most scenic courses.

View our Sponsorship Opportunities for all the details and benefits. If you’re ready to secure your sponsorship or have any questions, please contact Heather Tarpley at htarpley@thecgp.org.

We look forward to seeing you on August 20!

The Legal Corner provides the procurement community with an opportunity to share insights and comments on relevant legal issues of the day. The comments herein do not necessarily reflect the views of The Coalition for Common Sense in Government Procurement.

Authored by Lyndsay A. Gorton, Brian Tully McLaughlin, Jason M. Crawford, Kris D. Meade, and Nkechi Kanu; Crowell & Moring

On May 19, 2025, Deputy Attorney General Todd Blanche issued a Memorandum creating the Civil Rights Fraud Initiative that will “utilize the False Claims Act to investigate and . . . pursue claims against any recipient of federal funds that knowingly violates federal civil rights laws.” According to the Memorandum, though racial discrimination has “always been illegal,” the Administration posits that “many corporations and schools continue to adhere to racist policies and preferences—albeit camouflaged with cosmetic changes that disguise their discriminatory nature.” In an effort to prevent federal funds from being used in connection with or support of these purportedly racist policies and preferences, the Initiative will wield the power of the False Claims Act, the government’s most powerful tool to fight fraud, waste, and abuse.

This Memorandum follows and bolsters President Trump’s Executive Order (EO) No. 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (Jan. 21, 2025), often referred to as the “Anti-DEI Executive Order,” which seeks to end “illegal” diversity, equity, and inclusion (DEI) efforts by recipients of federal funding. Most pertinent, EO 14173 directed agencies to include terms in every federal contract or grant award requiring the contractor to agree that its compliance with applicable federal anti-discrimination laws is material to the government’s payment decisions, for purposes of the False Claims Act’s materiality element, and certify that it does not operate any programs promoting DEI that violate any applicable federal anti-discrimination laws. The EO is the subject of numerous ongoing legal challenges across the country. The Initiative appears to signal that the Department of Justice is initiating efforts to utilize the False Claims Act as an anti-DEI tool irrespective of the status of EO 14173’s certification provisions.

The Initiative will be co-led by the Department of Justice Civil Rights Division and the Civil Division’s Fraud Section to “aggressively” pursue the Initiative’s goals. Each of the ninety-three United States Attorney’s Offices around the country are also required to identify an Assistant United States Attorney to advance the Initiative’s efforts. The Initiative will also coordinate with DOJ’s Criminal Division, federal agencies, and states attorneys general and local law enforcement to pursue enforcement actions.

In addition to the federal and state partners, the Memorandum deputizes private individuals as DOJ “alone cannot identify every instance of civil rights fraud.” It therefore “strongly encourages” private individuals to file lawsuits under the False Claims Act, and by extension, share in any recovery of monies to the public fisc. Under the False Claims Act, private individuals can file qui tam lawsuits and stand in the shoes of the United States to vindicate alleged injuries to the United States and share in the recovery up to 30%. 31 U.S.C. § 3730. The Initiative seems to rely on the promise of sharing in potentially large recoveries as a strong incentive to bring anti-DEI lawsuits under the False Claims Act and is a call that prospective whistleblowers and the relator’s bar are sure to answer.

The timing of Deputy Attorney General Blanche’s call to action to relators is also noteworthy as the constitutionality of the False Claims Act’s qui tam provisions has been challenged in lawsuits throughout the country and is currently on appeal in the Eleventh and Third Circuits. The first, and so far only, case to declare the qui tam provisions unconstitutional under Article II’s Appointments Clause was decided less than a year ago on September 30, 2024. U.S. ex rel. Zafirov v. Fla. Med. Assocs., LLC, 751 F.Supp.3d 1293 (M.D. Fla. 2024). Following that decision, now-Attorney General Pam Bondi committed to defending the constitutionality of the False Claims Act in response to questioning from Senator Chuck Grassley (R-IA) during her confirmation hearings in January 2025. Since that time, DOJ has filed several statements of interest and briefs supporting the constitutionality of the qui tam provisions in district courts and the Eleventh Circuit. The issuance of the Memorandum may offer another sign that the current Administration will continue to support the constitutionality of the qui tam provisions, here as a means of extending the False Claims Act to reach alleged violations of federal civil rights laws.

Healthcare Spotlight: Funding for Community Care Increases 50 Percent in VA Appropriations Bill 

According to Military.com, the House Appropriations Committee released its FY 26 Military Construction, Veterans Affairs, and Related Agencies spending bill this Wednesday which includes $34 billion for community care at the Department of Veterans Affairs (VA). The VA’s total funding in the bill would be increased by $83 billion to about $453 Billion total. 

House Republicans are proposing that $34 billion of that total be allocated towards community care. This is a more than 50 percent increase over last year’s $22 billion of funding. Community care, like most medical care provided by the VA, falls under the VA’s discretionary budget, which is being raised 4 percent to $134 billion.  

The Trump Administration has begun taking actions to increase community care availability for veterans like removing the requirement for community care referrals to be reviewed by an additional VA physician.  

In addition, the bill includes $2.5 billion for the Electronic Health Record (EHR) Modernization program (a $1.1 billion increase year over year) and $18 billion for military construction ($480 million above last year’s level). The bill will be voted on by the Appropriations Committee next week. 

View from Main Street: M&A Size Recertification 180-day Rule  

The Small Business Administration’s (SBA) size rules generally provide that size is determined at the time of initial offer, including price.[1] SBA’s rules also require a firm to recertify if there is a change in size status due to an acquisition or merger, and address the impact of a recertification if the firm is no longer small.[2] In 2020 SBA issued a rule that for the first time provided that if the firm recertifies as other than small due to merger or acquisition within 180 days of offer, but prior to award, the firm is not eligible for award.[3]

In a recent size appeal decision, the agency issued the solicitation on August 1, 2023. Initial offers including price were due on October 2, 2023. The agency conducted discussions and requested final proposal revisions on May 17, 2024. The apparent successful offeror was acquired on September 26, 2024. On November 5, 2024, the agency issued notice of award to unsuccessful offerors. An unsuccessful offeror filed a size protest, arguing the prospective offeror was not eligible for award because it was acquired and became other than small within 180 days of its final proposal revision. The SBA Area Office dismissed the protest, and the unsuccessful offeror appealed to SBA’s Office of Hearings and Appeals (OHA).

The appellant argued that the 180-day rule does not use the term “initial offer,” unlike SBA’s general rule dictating that size is determined at the time of initial offer, including price. Further, the definition of offer in the Federal Acquisition Regulation defines an offer as a response to a solicitation that would bind the offeror to perform the contract, and therefore the final proposal revision is an offer under that definition.

SBA’s OHA considered the preamble to the final rule. In the final rule SBA sought to strike a balance based on comments from industry, essentially disqualifying firms from award of a set-aside contract when the acquisition occurs so close in time to the offer that the firm may have intentionally delayed the merger or acquisition to qualify for award. SBA also recognized that procurements can drag on for 18 months or more. At some point so much time has passed that it would be unfair to disqualify a firm for something that happens in the natural course of business and that could have been contemplated at the time of initial offer.

OHA also reasoned that the appellant’s interpretation, while simple, would lead to absurd results. Under the appellant’s interpretation, the apparent successful offeror would have been eligible for award for a short period of time starting in April through May 16, 2024, but the final proposal submission on May 17, 2024, would have restarted the 180-day clock, making the firm ineligible for award. OHA found that SBA did not intend for the 180-day clock to stop and start repeatedly throughout a long, drawn-out procurement process. SBA’s rules sought to provide certainty to industry and applying the 180-day rule to the initial offer, and the initial offer only, is the most rational interpretation of the rule. Thus, OHA found the Area Office decision was not based a clear error of fact or law and denied the appeal.[4]

Note: although not applicable to this size appeal, effective January 16, 2025, SBA revised its recertification rules to provide that a firm that recertifies as other than small after offer but prior to award is ineligible for award of a set-aside multiple award contract.[5]         

[1] 13 CFR 121.404(a).

[2] 13 CFR 125.12(a).

[3] 13 CFR 125.12(e)(2)(iii) (formerly 13 CFR 121.404(g)(2)(iii)).

[4] Secise, LLC, SBA No. SIZ-6337 (2025).

[5] 13 CFR 125.12(e)(2)(i);89 FR 102448.

Coalition Comments on Potential GSA GTIN/UPC Requirement 

The Coalition submitted comments on behalf of members last Friday in response to GSA’s Request for Information (RFI) on a potential requirement to use Global Trade Item Number (GTINs) for all commercial-off-the-shelf (COTS) products in the FAS Catalog Platform (FCP).   

GTINs are globally unique identifiers used to facilitate accurate product identification, standardization, and interoperability across supply chains. Examples include Universal Product Codes (UPC), European Article Number (EAN), Global Standards 1 (GS1), and ITF (standardized 14-digit barcode that utilizes the “Interleaved 2 of 5” symbology, commonly abbreviated as I2of5 or ITF). 

To access the Coalition’s GTIN comments, click here. In short, the Coalition informed GSA that the use of GTINs is not standard commercial practice for our member companies and that GTIN requirements may be especially counterproductive for highly configurable products like certain IT and furniture offerings. 

RFI on Essential Medicine Capacity of the Public Health Industrial Base  

The Administration for Strategic Preparedness and Response (ASPR) has issued an RFI on “Public Health Industrial Base Capabilities and Capacities: Essential Medicines.” The purpose of the RFI is to collect “market research on the domestic production capability and capacity of the Public Health Industrial Base (PHIB) as it relates to the list of essential medicines identified pursuant to section 3(c) of Executive Order 13944 of August 6, 2020.”  

Responses to the RFI are due June 13, 2025. 

Explore ‘Coalition Consults’ on VA and DoD Programs

The Coalition is proud to offer an exclusive resource for our healthcare members, Coalition Consults. Coalition Consults address key contracting programs at the Department of Veterans Affairs (VA) and Department of Defense (DoD) for medical/surgical supply and medical device companies. The consults provide basic information about the product scope of each contract, the contract terms and basic information about how companies can pursue these contracts including the appropriate VA contacts. Coalition Consults are currently available:

VA Contracts

  • VA Med-Surg Prime Vendor (MSPV) program
  • VA & DoD High Tech Medical Equipment (HTME) program
  • VA Medical Device Implant program
  • VA Non-Expendable (NX) program
  • VA Durable Medical Equipment (DME) program

DoD Contracts

  • DoD Medical Materiel Enterprise Standardization Office (MMESO) program
  • DLA Med-Surg and Manufacturer Direct Programs
  • DoD Medical Equipment Program
  • DoD MSPV
  • VA & DoD High Tech Medical Equipment (HTME) program

To access the Coalition Consults, click here. For any questions, please contact Michael Hanafin at mhanafin@thecgp.org.  

Discounted FPS Training Offerings for Coalition Members

To complement the Coalition’s current education and training offerings, we have partnered with Federal Publications Seminars (FPS) to provide even more online training courses to our members at an affordable price. FPS will provide Coalition members access to an annual training subscription to both the FPSOnline Professional and FPSOnline Premium curriculum at a 20 percent discount.

Use promo code 20CGPSUB at checkout to receive the discounted price.

Learn more and register here.

Group Pricing Available:

For individual pricing on a OnePass subscription, or to inquire about group pricing for all subscription types, please contact Catherine Restovich at Catherine@fedpubseminars.com.  

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