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Friday Flash 12/19/2025

Senate Passes ARCA Act: A Step Forward for VA Acquisition Reform

Last week, the U.S. Senate passed the Acquisition Reform and Cost Assessment Act (ARCA), a landmark piece of legislation that would strengthen acquisition management across the Department of Veterans Affairs (VA). The Coalition for Common Sense in Government Procurement (Coalition) applauds this significant milestone, which would help ensure that veterans receive high-quality care through a coordinated, efficient and transparent procurement system. ARCA represents the most consequential reform of VA acquisition management in more than a generation, marking a transformative moment for the department and the veterans it serves.

On May 21, the U.S. Senate Committee on Veterans’ Affairs held a legislative hearing that included consideration of ARCA. The Coalition was honored to be invited by Chairman Jerry Moran to provide a statement for the record addressing the proposed legislation and its importance to improving VA procurement operations.

Elevating VA Acquisition Management

ARCA establishes an Assistant Secretary of Veterans Affairs for Acquisition, a new senior-level position that will unify and oversee procurement activities across the department. Under the legislation, all VA contracting officers and acquisition centers will be consolidated under this office, creating a streamlined, departmentwide framework.

Consolidating procurement operations under a single acquisition leader would help standardize practices, improve coordination across the enterprise, and strengthen communication with industry partners. These reforms together would support more efficient management of acquisition and logistics resources. This restructuring also adds accountability to address the challenge of open-market purchase card buys for medical supplies, which increase costs and weaken the integrity of the VA’s supply chain.

In addition, this centralized structure would enable the VA to approach procurement with greater strategic focus. ARCA marks an essential step in ensuring timely, cost-effective delivery of products and services to veterans.

Positioning the VA to Adopt Best Practices

ARCA also lays the foundation for adopting commercial best practices and strengthening the VA’s supply chain operations. With procurement functions operating under a unified structure, the VA will be better positioned to enhance purchasing power, improve data visibility, and reduce administrative burdens across the acquisition life cycle.

ARCA would further allow the VA to efficiently manage and distribute its acquisition personnel and logistics resources to meet the evolving needs and challenges of veterans. These reforms would advance transparency, efficiency, and collaboration across the enterprise, reinforcing a stronger supply chain and supporting improved outcomes for veterans. These reforms would promote more consistent delivery of high-quality products to the VA’s healthcare system.

This bipartisan legislation will now be considered by the U.S. House of Representatives. The Coalition and industry stand ready to support the VA in its implementation of procurement reforms. ARCA represents a significant step toward strengthening the VA’s acquisition system to deliver best value to veterans.

Welcome Administrator Edward Forst

It is with great pleasure that The Coalition for Common Sense in Government Procurement recognizes the Senate’s confirmation of Edward Forst last night to serve as Administrator of the General Services Administration.

Mr. Forst brings a distinguished record of leadership across the public and private sectors. His past roles include serving as Chairman of Lion Capital, as well as senior positions at Cushman & Wakefield, Goldman Sachs, and the U.S. Department of Treasury.

The Coalition congratulates Administrator Forst on his confirmation and looks forward to working with him to advance common sense in government procurement and support an efficient, effective, and competitive federal marketplace.

RFO, OASIS+ Phase II, and More at the Winter Training Conference

As the Federal procurement community prepares for a transformative year, the Coalition’s Winter Training Conference: The Revolutionary Federal Market is set to deliver the essential updates, analysis, and perspectives contractors need to begin 2026 with clarity. Taking place on January 14–15 at the Fairview Park Marriott in Falls Church, VA, this two-day event offers a timely opportunity to get ahead of sweeping policy changes and marketplace shifts already taking shape.

With the holiday season upon us, now is the perfect time to secure your spot before stepping away for a well-earned break! Below is a preview of several key updates and priority topics we will explore in January. We look forward to seeing you there!

To register, click here. For questions or assistance with registration, please contact Madyson Whiting at mady.whiting@thecgp.org. Please use the link to secure your room in our block at the discounted rate: Book your group rate for CGP Conference

Governmentwide Day Highlights (January 14)

  • Keynote Address: Policy and Program Priorities of the New Federal Market
  • Luncheon Keynote Address with OFPP Administrator
  • The Revolutionary FAR Overhaul – What’s Next?
  • GSA’s Consolidation Action Plan
  • Updating MAS Ordering Guidance to Support FAR Revolutionary Overhaul Enhancements
  • The New IT GWAC Market
  • Integrated Award Environment (IAE)/SAM.gov
  • The New Schedules Market: Transactional Data Reporting and More

View the full Governmentwide Day agenda here. 

Healthcare Day Highlights (January 15)

  • Keynote Addresses —The Future of Veteran Care in the Revolutionary Federal Market
  • VA Acquisition Leadership Panel 
  • Federal Budget and Legislative Updates
  • Impacts of the Revolutionary FAR Overhaul on Federal Healthcare Contractors & More
  • VA Medical/Surgical Prime Vendor Program
  • DHA Pharmaceutical Program
  • VA Federal Supply Schedule (FSS) Program
  • VA Pharmacy Program
  • VA Community Care Program

View the full Healthcare Day agenda here. 

There’s Still Time! Secure Your Sponsorship Now for the 2025-2026 Winter Training Conference

There is still time to secure your company’s sponsorship for the 2025-2026 Winter Training Conference: The Revolutionary Federal Market!

Sponsoring the Coalition’s conference provides outstanding brand visibility and the opportunity to demonstrate thought leadership before a highly engaged audience of procurement professionals and Federal Government officials. 

Sponsorship of the Coalition’s flagship event provides your organization with many benefits, including: 

  • Establishing your company as a leader in the industry; 
  • Demonstrating your thought leadership to a highly engaged audience of procurement professionals and Federal Government officials; 
  • Associating your company with a well-known event; 
  • Promoting your company’s brand; 
  • Reaching new audiences; 
  • Generating quality leads; 
  • Showcasing your products and services; and 
  • Networking and establishing new relationships. 

To learn more, view the Sponsorship Prospectus. 

Thank you to our current sponsors!

     

Ready for January? Start Planning in the Conference App

The mobile app for the Coalition’s 2025-2026 Winter Training Conference is available for registrants.

If you have already registered for the conference, simply follow these instructions to download the app and log in. All registrants will also receive an email next week with the instructions on how to access the app. If you have not yet registered for the Winter Training Conference, be sure to reserve your spot here! All future registrants will receive app instructions within one business day. 

By logging in today, you will be able to: 

  • Set up your profile and begin networking with other attendees before the conference kicks off. 
  • Submit questions for speakers ahead of time, helping shape the information and conversations you want to hear. 
  • Personalize your agenda to make sure you don’t miss the sessions most important to you. 
  • Stay in the loop with real-time conference announcements and updates delivered directly through the app. 

Special thank you to our Conference App Sponsor, Veterans Healthcare Supply Solutions, for enhancing the conference experience for everyone at the event through the app. 

Congress Passes FY26 NDAA

Following House passage last week, the Senate voted 77–20 on Wednesday to approve the compromise National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2026. The bill now heads to the President for signature.

The bipartisan package authorizes $901 billion in defense spending, roughly $8 billion above the Administration’s request, and establishes next year’s defense and national security priorities. The measure includes a nearly four percent pay raise for service members, investments in military housing, restrictions on certain U.S. investments in China, and continued support for Ukraine.

The final NDAA text clarifies the status of several policy provisions Congress debated during negotiations. Key items affecting contractors include:

  1. TMF Reauthorization Not Included 

NextGov reports that the Technology Modernization Fund (TMF), administered by GSA, was not reauthorized in the NDAA. The TMF provides agencies with funding to accelerate information technology (IT) modernization projects, with the expectation that savings generated by those improvements would replenish the fund. 

With the TMF’s authorization having expired on December 12, the approximately $160 million remaining in the fund is now effectively frozen until Congress acts. The White House has expressed support for reauthorizing the program, but no legislative vehicle is apparent. 

  1. DoD Right-to-Repair Not Included 

Federal News Network reports that despite bipartisan interest, most “right-to-repair” provisions did not make it into the final NDAA. The House-passed version would have required the Department of Defense (DoD) to secure access to technical data and necessary software before awarding a contract. The Senate version included language requiring defense contractors to share repair and maintenance instructions with the government. Both provisions were ultimately removed during negotiations. 

However, the final NDAA does direct DoD to establish a system to manage, store, and evaluate technical data provided by contractors to ensure compliance with existing contractual requirements. 

  1. Withholding of Payments for Frivolous Bid Protests 

JD Supra reports that the NDAA includes a provision allowing agencies to withhold up to five percent of certain payments from an incumbent contractor that files a frivolous bid protest. The withholding authority applies only when the Government Accountability Office dismisses the protest for lacking a factual or legal basis. 

  1. BIOSECURE Act Provisions Included 

The NDAA includes language that bans the government from acquiring services or equipment from “biotechnology companies of concern.” For more analysis, please see this week’s “Legal Corner.” 

GSA to Refresh Major GWACs by January  

Meritalk reports that the General Services Administration (GSA) will refresh all of its major governmentwide acquisition contracts (GWACs) and multiple award vehicles by the end of January, according to Federal Acquisition Service (FAS) Deputy Commissioner Laura Stanton. Speaking at an event last week, Stanton said that GSA is moving quickly to embed recent Federal Acquisition Regulation (FAR) changes directly into the agency’s most widely used contracting programs, including OASIS+ and Alliant 2. Stanton emphasized that the FAR deviations tied to the Revolutionary FAR Overhaul (RFO) will be incorporated across these vehicles in the coming weeks. 

A major step in that direction came with Multiple Award Schedule (MAS) Refresh 30, released in November. The MAS Program now includes dozens of revised and streamlined FAR clauses. Stanton urged industry to review Refresh 30 closely. “We updated 53 clauses and provisions. We have five new clauses, and we’ve eliminated 36,” she said, describing Refresh 30 as the first wave of RFO-driven updates. 

Some changes to GWACs and multiple award contracts are already underway. Alliant 2, for example, has begun enabling blanket purchase agreements (BPAs), and Stanton indicated that OASIS+ and other vehicles will follow in the next several weeks. 

OFPP Seeks Public Input for Next Phase of FAR Overhaul 

The RFO is moving into its next phase in 2026, and the Office of Federal Procurement Policy (OFPP) is seeking broad public input to help shape it. To support this effort, OFPP has launched a new IdeaScale community designed to collect feedback from the acquisition workforce, industry, and other stakeholders on ways to streamline and modernize the FAR. 

Through the platform, participants can submit ideas on practices agencies should start, stop, or refine as the government works toward a rewritten and simplified FAR. Community members may also view, comment on, and vote for ideas posted by others, helping OFPP identify the most impactful recommendations. 

OFPP describes this as a key opportunity to contribute to a “historic initiative” that aims to reset the foundation of federal buying. The IdeaScale community will accept feedback through January 7, 2026. 

New Consolidated RFO Model Deviations PDF Now Available 

Based on feedback, the FAR Council has released a full PDF of all updated model deviations as part of the ongoing Revolutionary FAR Overhaul (RFO) Initiative. The RFO PDF, which includes all model deviations as well as the consolidated parts 2 and 52, is being provided to support ease of searching content within the RFO.  

View this resource here. 
 

White House Releases Executive Order Restricting State Regulations on AI 

Last week, the White House issued a new Executive Order (EO) establishing a National Policy Framework for Artificial Intelligence (AI), aimed at reducing regulatory barriers and promoting nationwide AI adoption. The order seeks to prevent inconsistent state AI standards by limiting state laws that conflict with the Administration’s AI policy. 

The EO creates an AI Litigation Task Force, which will be responsible for challenging state AI laws deemed inconsistent with the national framework, particularly laws that may regulate interstate commerce, require AI models to alter truthful outputs, or impose disclosure obligations that raise constitutional concerns. 

The EO also directs the Secretary of Commerce to review existing state AI laws within 90 days and identify those that conflict with Federal policy. Based on that assessment, Commerce may recommend restricting certain types of Federal funding for states that maintain AI laws deemed “onerous” under the order. 

Additional provisions require Federal agencies to: 

  • Evaluate and modify contracts to ensure compliance with the National AI Policy Framework; 
  • Consider conditioning discretionary grants on whether states avoid adopting conflicting AI regulations; and 
  • Work with the Federal Communications Commission and the Federal Trade Commission on potential standards and preemption policies related to AI reporting, disclosure, and deceptive practices. 

OMB Issues New Requirements to Ensure “Unbiased” and “Truth-Seeking” AI in Federal Procurement 

The Office of Management and Budget (OMB) has issued a new memo, “Increasing Public Trust in Artificial Intelligence Through Unbiased AI Principles,” establishing governmentwide requirements to ensure that AI large language models (LLMs), procured by Federal agencies produces truthful, objective outputs free from ideological influence. 

Under the memo, LLMs acquired by the Federal Government must: 

  • Produce reliable, truth-seeking outputs, prioritizing historical accuracy, scientific inquiry, and objectivity;  
  • Remain ideologically neutral, avoiding responses influenced by partisan or ideological judgments; and 
  • Acknowledge uncertainty where information is incomplete or conflicting. 

Agencies must incorporate these requirements into new contracts, modify existing contracts as necessary, and update procurement policies to align with the Unbiased AI Principles. When procuring LLMs, agencies are directed to obtain sufficient information from vendors to assess compliance while avoiding requests for sensitive proprietary data. Vendors must instead provide enough documentation for agencies to evaluate risk management practices and adherence to the AI principles. 

Agencies are required to update internal procedures by March 11, 2026, including establishing mechanisms for reporting LLMs that violate the new standards. The memo will sunset two years after issuance, unless extended by the OMB Director. 

FedRAMP Announces First Entrants in 20x Phase 2 Pilot 

On December 10, the Federal Risk and Authorization Management Program (FedRAMP) published a blog announcing the initial participants in its 20x Phase 2 pilot, which aims to automate and accelerate security assessments for cloud service offerings seeking government authorization. FedRAMP is using the pilot to explore new engineering-driven approaches to streamline the authorization process. 

Phase 2 will include two cohorts, and the first group of participants has now been selected. Cohort 1 features three cloud offerings, including Confluent Cloud for Government, Meridian LMS, and Paramify Cloud. FedRAMP’s blog post links to each provider’s video proposal, offering insight into the engineering approaches and automation strategies that applicants can use as models when preparing submissions. Proposals for the second cohort, which will include up to seven participants, are due January 9, 2026. 

FedRAMP also highlighted key program updates in a letter from Director Pete Waterman to the FedRAMP Board. According to the letter, Phase 2 of the 20x pilot will conclude at the end of fiscal year (FY) 2026 Q2, with Phase 3 beginning in FY26 Q3 and Q4 to support wider adoption of these new assessment capabilities. Waterman additionally noted that the first three AI Prioritization FedRAMP 20x Low authorizations are on track to be awarded in January. 

VA Announces Plan to Restructure VHA Management to Improve Veteran Care 

The Department of Veterans Affairs (VA) has announced its intent to reorganize the management structure of the Veterans Health Administration (VHA) as part of a multi-year effort to strengthen healthcare delivery for veterans. The reorganization aims to empower local hospital directors, eliminate duplicative layers of bureaucracy, and ensure consistent application of VA policies across all medical facilities. 

The decision follows multiple independent reviews from the VA Inspector General, the Government Accountability Office (GAO), and others, which identified governance weaknesses, unclear roles, and overlapping management responsibilities that slow decision-making and hinder service to veterans. 

According to the VA, the new structure will streamline oversight by: 

  • Establishing a VHA Central Office responsible for policy goals, financial management, oversight, and compliance; 
  • Directing Operations Centers and Veterans Integrated Service Networks (VISNs) to translate those policies into operational, quality, and performance standards to guide VA’s more than 1,300 medical facilities; and 
  • Providing clearer guidance and expanded decision-making authority to VA Health Care Systems, including over 170 medical centers and nearly 1,200 outpatient sites. 

The VA emphasized that the reorganization is not a reduction in force. Staffing at medical centers and clinics will remain unchanged, and the department does not anticipate significant shifts in overall staffing levels. Precise organizational and personnel changes will be announced in early 2026, with implementation occurring over the following 18 to 24 months. 

VA Releases RFP for Next Generation of Community Care Contracts 

The VA has issued a new Request for Proposals (RFP) to establish the next generation of community care contracts, aiming to expand choice and improve the quality of care available to veterans over the next decade. The VA’s Community Care program allows veterans to receive health care from non-VA providers at the department’s expense and now accounts for roughly 40 percent of all VA-funded care. 

The current community care contracts, signed in 2018 following enactment of the MISSION Act, are set to expire in 2026, prompting the VA to begin the procurement process for new third-party administrators. 

According to the VA, the new contracts are designed to strengthen community care in four key ways: 

  • Increased choice for veterans by leveraging indefinite delivery/indefinite quantity (IDIQ) contract structures;  
  • Improved care quality through heightened standards; 
  • Improved VA oversight of community care through expanded data sharing; and 
  • Contractual flexibility as the IDIQ structure lets the VA issue multiple competitive task orders. The VA may also on-and-off board contractors. 

Updated FY25 VA Data Sets Now Available for Members 

To increase the number of valuable tools available for members, the Coalition has compiled several data sets pertaining to VA Medical Centers’ procedures, diagnoses, and product spend. Data through FY25 is now available. Below is a description of the VA data reports that the Coalition can provide to healthcare members based on areas of interest to their business: 

  • Diagnosis data by each VA Medical Center: Members can request a report by providing the relevant International Classification of Diseases (ICD-10) codes of interest. 
  • Procedure data by each VA Medical Center: Members can request a report by providing the relevant Current Procedural Terminology (CPT) codes of interest. 
  • Prosthetic (medical implants, DME) product spend by VA Medical Center: Members can request a report by providing the relevant Healthcare Common Procedure Coding System (HCPCS) codes for items managed by VHA Prosthetics. 
  • VAMC Surgeries: A report detailing total surgical procedures performed at individual VA Medical Centers. 
  • Total Veterans Health Administration (VHA) Surgeries: A systemwide summary of surgical volume across the entire VHA. 

For any data requests or related questions, please contact Michael Hanafin at mhanafin@thecgp.org.

Pentagon Unveils GenAI.mil to Accelerate AI Adoption Across the Department 

The Department of Defense (DoD) has announced the launch of GenAI.mil, a secure generative AI platform now available on the desktops of all military, civilian, and contractor personnel. The tool is designed to accelerate departmentwide adoption of AI and enhance workforce efficiency. 

GenAI.mil currently hosts Gemini for Government, a specialized version of Google’s Gemini model approved to handle controlled unclassified information. A system banner provides users with clear reminders about what data may and may not be shared on the platform. According to DoD, additional American-made frontier AI capabilities will be added in the near future. 

In an email announcing the launch, Secretary of War Pete Hegseth described GenAI.mil as “a giant step toward mass AI adoption across the department” and emphasized his expectation that personnel begin integrating the tool into their daily workflows. The platform can support a range of tasks, including drafting and refining documents, analyzing information, reviewing code for security vulnerabilities, and processing satellite imagery. 

OPM Launches U.S. Tech Force 

The Office of Personnel Management (OPM), working in coordination with OMB, GSA, and the White House Office of Science Technology and Policy, has announced the launch of the U.S. Tech Force, a new cross-government program aimed at recruiting top technologists to support Federal modernization efforts. 

The initiative seeks to bring engineers, data scientists, and technology leaders into government to work on mission-critical technology challenges. Participants will also receive technical training developed in partnership with leading private-sector experts. 

As part of the announcement, OPM released the initial roster of private-sector partners supporting Tech Force. These include: Adobe, Amazon Web Services, AMD, Anduril, Apple, Box, C3.ai, Coinbase, Databricks, Dell Technologies, DocuSign, Google Public Sector, IBM, Meta, Microsoft, Nvidia, OpenAI, Oracle, Palantir, Robinhood, Salesforce, SAP, ServiceNow, Snowflake, Synopsys, Uber, Workday, xAI, and Zoom. OPM noted that this list is expected to grow over time. 

The Tech Force will deploy talent across a wide range of agencies, including major departments such as State, Treasury, DoD, Health and Human Services, VA, and Homeland Security, to advance modernization and strengthen Federal technology capabilities. 

The Legal Corner provides the procurement community with an opportunity to share insights and comments on 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 Joy E. Sturm, Allison D. Pugsley, Tim Bergreen, Michael N. Druckman, and Ajay Kuntamukkala; Hogan & Lovells

The final FY 2026 National Defense Authorization Act (NDAA) was released on December 7, inclusive of a modified version of the Senate-passed BIOSECURE Act from October. This final bill maintains the core structure of the Senate’s BIOSECURE text while making several targeted changes. Congress has kept the government-wide prohibition concept intact, while closing a “gap” that could have resulted in federal health program impact, limiting the scope of coverage, narrowing the “knowledge” requirement, and reducing potential operational friction in areas like overseas health care.

In terms of timing, the NDAA is on a relatively fast track to become law. The House of Representatives passed the NDAA on December 10. The Senate is expected to pass the NDAA during the week of December 15. The White House has issued a formal Statement of Administration Policy supporting the NDAA, stating that the President will sign the NDAA into law when it is presented to him for signature. Depending on exactly when the Senate passes the NDAA, President Trump is expected to sign the NDAA into law either during the week of December 15 or the following week. 

The basic structure of BIOSECURE remains the same from the version included in the Senate-passed NDAA: executive agencies will be barred from procuring biotechnology equipment or services from “biotechnology companies of concern” and from entering into contracts performed using such equipment or services. Related prohibitions will apply to certain grants, loans, and cooperative agreements.

The term “biotechnology companies of concern” continues to include 1) companies on a list to be published by the Office of Management and Budget (“OMB”), as well as 2) companies included on Department of Defense/War (“DoD”)’s Section 1260H list of Chinese military companies. OMB remains responsible for establishing and managing an interagency process to identify biotechnology companies of concern, maintaining and updating a public list, and coordinating with the Federal Acquisition Regulation (“FAR”) Council on necessary changes to procurement regulations.

Passage and enactment are virtually certain. Once the NDAA is signed, OMB will need to establish the designation process, consult with national security and health agencies on criteria and specific entities, and coordinate with the FAR Council on regulatory execution.

Some noteworthy changes in the final bill:

  • First, the conference text narrows the automatic capture of entities on DoD’s Section 1260H list of Chinese military companies. Under the Senate version, 1260H status alone effectively made a firm a biotechnology company of concern, even if the firm in question had no connection with biotechnology. The final bill now requires a biotechnology nexus: a 1260H-listed entity must also be involved to some extent in manufacturing, distributing, providing, or procuring biotechnology equipment or services. Recent news reports indicate that a Pentagon roster of companies to be added to the 1260H list in the next update includes WuXi Apptec.
  • Second, affiliates of companies of concern are no longer “automatically” covered by BIOSECURE by virtue of their relationship to a covered company. The earlier Senate text had pulled in any subsidiary, parent, affiliate, or successor of a covered entity as a “biotechnology company of concern,” so long as it met only the “foreign adversary governance/control” criterion. The final bill drops the term “affiliate” entirely and only captures affiliates that are parents, subsidiaries, or successors. And these entities must meet the full set of criteria that apply to directly designated entities, including both the foreign adversary nexus and the specific biotechnology and national security risk factors.
  • Third, the scienter standard for contractors is narrowed to require actual “knowledge.” The Senate-passed and earlier versions of the BIOSECURE bill broadly covered contractors that would “know or have reason to believe” that performance of a federal contract would require the use of prohibited biotechnology equipment or services. The final bill pares the restriction back to contracts that the contractor “knows” will require such use, a change that is no doubt welcome to contractors who may not have full visibility of relevant supply chains.
  • Fourth, the final bill addresses potential Federal health program impact. We had flagged in our October 25, 2025 alert that although BIOSECURE applies only to federal procurement contracts, and not to reimbursement/payer contracts such as those supporting federal health programs, the bill could have “collateral” federal health program impact on pharma/biotechnology manufacturers supplying BIOSECURE-restricted product. The final text attempts to protect manufacturers from this impact by providing that a company will be deemed to be in compliance with its statutory requirement to make product available for procurement on Federal Supply Schedule contracts, and thus not blocked from Medicare Part B and Medicaid, if the Secretary of VA determines that the company “would comply” with the statutory requirement but for the prohibitions of BIOSECURE.
  • Fifth, the final bill clarifies a politically sensitive topic: overseas health care for U.S. government personnel and their families. The earlier Senate-passed bill excepted U.S. employees and uniformed service members whose official duty stations are overseas, as well as certain contractor employees supporting them. The final bill expands that carve-out to explicitly include dependents, TRICARE-covered beneficiaries, and other categories of beneficiaries for whom care is provided by a U.S. department or agency, while maintaining the contractor-employee component.

A January 7, 2025, Federal Register Notice (“90 FR 1105) regarding additions to the 1260H List also published the Reconsideration Process. Entities on the 1260H List seeking reconsideration must submit the following information to DoD:

  1. Entity Information:
  1. The listed entity’s name and mailing address (including email address).
  2. An authorized representative’s name and mailing address (including email address).
  3. Statement of Reconsideration:
  1. A statement indicating the entity’s intent to request reconsideration of the Department’s determination.
  2. A detailed description, supported by evidence, explaining why the entity should be removed from the 1260H List.
  3. Additional Information:
  4. Arguments and evidence that demonstrate either 1) an insufficient basis for the listing, or 2) that the circumstances leading to the listing no longer apply.

We note, as a final point, that the timing profile is adjusted at the margins. BIOSECURE prohibitions still do not take effect until after OMB has acted and the FAR Council has amended the regulations. However, in the earlier Senate-passed version, the non-1260H entities added through the OMB process did not become subject to the procurement ban until 180 days after the FAR revisions. The final bill shortens that period to 90 days. For 1260H companies, the FAR implementation period of 60 days has not been revised.

Next steps

If you have questions or would like to discuss, please reach out to our BIOSECURE team: Joy Sturm, Allison Pugsley, Timothy Bergreen, Mike Druckman, Ajay Kuntamukkala, Ari Fridman, Cybil Roehrenbeck, Ashley Roberts, and Ashley Ruhe.

VA Issues MSPV Solicitation, One-on-One Meetings at the Winter Training Conference

Yesterday, the VA Medical/Surgical Prime Vendor (MSPV) team released the updated solicitation for consumable commodities in support of the MSPV program catalogue. Offers are due on January 19, 2026 at 5 PM (ET). 

We are excited to share that the VA MSPV program team will hold one-on-one meetings with attendees on Wednesday, January 14 (governmentwide day) as part of the 2025-2026 Winter Training Conference. To schedule a 15-minute meeting, please reach out directly to the appropriate contact. Meetings will be scheduled on a first-come/first-served basis.

A list of all available VA representatives, along with their contact information, is provided below.

If you have not yet registered for the Winter Training Conference, you may do so here. Please note that conference registration is required in order to participate in the one-on-one meetings.

Med/Surg Supply BPA One-on-One Meetings: January 14 (Day One of the Conference)

Jeremy Boston: Jeremy.Boston@va.gov

Pedro Jaime Catinchi: Pedro.CatinchiJaime@va.gov

Brett Cook: Brett.Cook@va.gov

Katherine Corcoran: Katherine.Corcoran@va.gov

Jon-Paul Grizzle: Jon-Paul.Grizzle@va.gov

Edward Lyke: Edward.Lyke@va.gov

Crystal Martin: Crystal.Martin5@va.gov

Matthew McDonell: Matthew.McDonell@va.gov

Princess Mersha: Princess.Mersha@va.gov

Jeremy Parker: Jeremy.Parker2@va.gov

Michael Pierson: Michael.Pierson@va.gov

Sarah Scott: Sarah.Scott1@va.gov

Melanie Stockman: Melanie.Stockman@va.gov

Rashaun Thomas: Rashaun.Thomas@va.gov

Available Time Slots

10:00 – 10:15am
10:15 – 10:30am
10:45 – 11:00am
11:15 – 11:30am
11:30 – 11:45am
11:45 – 12:00pm
3:15 – 3:30pm
3:45 – 4:00pm
4:00 – 4:15pm
4:15 – 4:30pm

If you have any questions, please contact Michael Hanafin at mhanafin@thecgp.org. We look forward to seeing you at the conference in January! 

Off the Shelf: Grading the FAR Overhaul  

Jessica Tillipman, Associate Dean for Government Procurement Law at The George Washington University Law School, joined Off the Shelf to discuss the Revolutionary FAR Overhaul (RFO) and AI the Federal procurement.  

During the interview, Tillipman graded the RFO and shared her insights on its major changes, noting that the reorganization and consolidation represent a positive step toward modernizing and improving Federal procurement. She also analyzed how the key regulatory shifts could impact agencies and industry. 

Tillipman discussed the use of AI to improve government procurement efficiency, using a “Wedding Cake” model to help visualize the fundamentals of AI and how its layered structure supports procurement applications. She emphasized the need to carefully navigate key policy considerations, providing practical advice on how Federal entities might responsibly integrate AI into their contracting and acquisition processes. 

Listen to the full interview here.   

Register for the Small Business Summit! Jan. 13 

On January 13, the Coalition will host its third annual Small Business Summit, a half-day forum featuring key insights and analyses into the latest developments regarding small business policy, subcontracting, teaming, joint venture agreements, and more.

The program will consist of valuable sessions featuring experts from government and industry, and the chance to network with peers in the procurement community. The Summit is an excellent opportunity for both small and large businesses to increase their knowledge about small business policy and what makes for a successful, sound business relationship.

Small Business Administration (SBA) Regulatory Update 
John Klein, SBA Deputy General Counsel, will provide a Regulatory Update, giving key insights into recent and upcoming regulatory changes impacting small businesses. Attendees will be informed on the latest SBA policies and how they affect compliance and opportunities in federal contracting.

Small Business Subcontracting
The Summit also features a panel on small business subcontracting, with perspectives and insights from large and small businesses. Speakers will discuss compliance considerations, opportunities, and practical strategies for building successful partnerships in today’s federal marketplace. Attendees will gain a clearer understanding of how primes and subs can work together to meet subcontracting goals and deliver best value to government customers.

SBA Policies and Programs Update
Finally, there will be an update on the latest SBA government contracting programs and policies. Experts will review recent regulatory developments, upcoming changes affecting small business eligibility and certifications, and new tools and initiatives designed to support small businesses. 

This event is complimentary to all Coalition members, and both in-person and virtual attendance are available! Register here. For any assistance, please contact Madison Whiting at mady.whiting@thecgp.org.  

Webinar – Overview of the NDAA for Fiscal Year 2026, Jan. 22

Join the Coalition and Moshe Schwartz, President of Etherton and Associates, Inc., on January 22 from 12:00 – 1:00 PM (ET) for an Overview of the National Defense Authorization Act (NDAA) for Fiscal Year 2026.

During the webinar, Moshe will highlight trends and focus areas of the NDAA, including: 

  • Acquisition;
  • The Industrial Base;
  • Cybersecurity Provisions; and
  • More

To register, click here. For assistance with registration, please contact Mady Whiting at Mady.Whiting@thecgp.org. 

Webinar – OASIS+ Phase II: New Domains. Continuous Enrollment. Bigger Possibilities, Jan. 27

GSA is set to reopen all six OASIS+ solicitations on January 12, 2026, under a continuous enrollment model—introducing five new service domains that expand the playing field for professional services contractors. This update reflects Executive Order 14240 and GSA’s push to simplify acquisition and consolidate spend.

On January 27 from 12:00 – 1:00pm EST, please Join Leo Alvarez, Principal at Baker Tilly, Dylan Schreiner, Government Contractor Solutions Senior Manager at Baker Tilly, and the Coalition for a practical briefing on Phase II of OASIS+. Leo and Dylan will cover the upcoming pre-amendment notice, draft scorecards, and strategies to position your firm for success.

Topics include:

  • The five new domains and their implications;
  • Preparing for continuous enrollment; and
  • Teaming and qualification best practices.

Whether you’re an incumbent or a newcomer, this session will help you navigate the next chapter of OASIS+.

To register, click here. For assistance with registration, please contact Mady Whiting at Mady.Whiting@thecgp.org. 

Webinar – Commerciality Considerations of DoD’s Memo on “Transforming the Defense Acquisition System into the Warfighting Acquisition System,” Jan. 29

On November 7th, the Department of War released a memorandum outlining its initiative to “Transform the Defense Acquisition System into the Warfighting Acquisition System.” Join the Coalition on January 29th from 12:00 – 1:00pm EST for a presentation by Peter Terenzio of Covington and Mike Tomaselli of Chess Consulting as they examine the memo’s major themes and the implications for government contractors.

The session will include a focused discussion on the regulatory framework governing commercial contracting, given the memorandum’s emphasis on expanding the defense industrial base through a “commercial first” strategy. Topics will include:

• Key themes and objectives identified in the memo;
• FAR Part 12 vs. FAR Part 15 (commercial vs. negotiated acquisitions);
• Definitions of commerciality under FAR 2.101;
• Commercial item determinations and DCMA’s role; and
• Alignment with the FAR Overhaul and proposed CAS changes.

To register, click here. For assistance with registration, please contact Mady Whiting at Mady.Whiting@thecgp.org. 

2025 Small Business Regulatory Year in Review, Feb. 4

The Coalition will host a virtual 2025 Small Business Regulatory Year in Review presentation on February 4 from 12:00-1:00 PM (ET)! The event features industry experts David Black, Partner at Holland and Knight, Ken Dodds, Vice President of Acquisition Policy at The Coalition for Common Sense in Government Procurement, and Jon Williams, Partner at PilieroMazza, who will provide insights on the regulatory cases and updates of the past year that affected both large and small business contractors.

During the event, Black, Dodds, and Williams will cover a wide range of topics, including observations on:

  • Small Business Administration (SBA) updates;
  • Office of Hearings and Appeals (OHA) cases;
  • Government Accountability Office (GAO)/Court of Federal Claims (COFC) decisions; 
  • And More

Small and large businesses are encouraged to attend. If you have any questions in advance of the event, please contact Joseph Snyderwine at Jsnyderwine@thecgp.org. 

To register, click here. For assistance with registration, please contact Mady Whiting at Mady.Whiting@thecgp.org. 

Earn Conference Discounts through the Member Referral Program! 

The Coalition for Government Procurement is excited to offer our Member Referral Program! 

For each new member your organization refers, and then joins the Coalition, you’ll receive a $250 discount toward registration for either the Spring or Fall Training Conference. There’s no limit to how many discounts you can earn!

Start referring today to enjoy the rewards while helping expand the Coalition’s membership base and advancing our mission of promoting common-sense procurement.

To make a referral or if you have questions about the program, please contact Heather Tarpley, Vice President of Business Development & Sales, at HTarpley@thecgp.org.

Thank you for being a valued member of the Coalition. Your support is key to our success!

All GWAC Holders: Take the GWAC Survey

The Coalition is surveying its member companies that currently hold the following GWAC contracts: 

  • Alliant 2 
  • NASA SEWP 
  • CIO-SP3 
  • VETS 2 
  • STARS 3 

The purpose of the survey is to identify the strengths and potential areas of improvement for these GWAC vehicles for key stakeholders like the Office of Management and Budget (OMB) and the General Services Administration (GSA). 

Take the GWAC Survey here. 

All current GWAC contract holders are encouraged to participate. Please note that individual company names will NOT be shared with the Government. The survey responses are for non-attribution.

If you have any questions, please contact Michael Hanafin at mhanafin@thecgp.org.

FY24 VA Data for Healthcare Members 

To increase the number of valuable tools available for members, the Coalition has compiled several data sets pertaining to VA Medical Centers’ procedures, diagnoses, and product spend. Below is a description of the different VA data reports that the Coalition can provide to healthcare members based on areas of interest to their business:    

  • Diagnosis data by each VA Medical Center: Members can request a report by providing the relevant International Classification of Diseases (ICD)-10 codes of interest to their business.   
  • Procedure data by each VA Medical Center: Members can request a report by providing the relevant Current Procedural Terminology (CPT) codes of interest to their business.   
  • Prosthetic (medical implants, DME) product spend by VA Medical Center: members can request a report by providing the relevant Healthcare Common Procedure Coding System (HCPCS) codes of interest to their business for items managed by VHA Prosthetics.   

For any data requests or related 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 Restovichat Catherine@fedpubseminars.com.  

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