FAR & Beyond: What’s Next for Value-Added Resellers?
On June 2nd, the General Services Administration’s (GSA) Federal Acquisition Service (FAS) posted on its Interact Multiple Award Schedule (MAS) Community site a “Summary of Results of Request for Information (RFI) about IT Hardware procured through Value Added Resellers (VAR)” (the Summary). The Summary outlined key insights gleaned from the 136 responses received in response to FAS’s January 2026 RFI. The RFI sought commercial market information from stakeholders “to enhance the Government’s understanding of the Value-Added Reseller marketplace under SIN 33411” of the MAS solicitation.
The Summary highlights nine insights from the 136 responses. The insights are divided into four topic areas and address the following: (1) Widely Accepted Commercial Definitions for Resellers and VARs; (2) Value is in the service, not product markup; (3) Recommended Pricing and Evaluation Framework; and (4) Government Work is more costly. Let’s unpack these insights.
First, FAS’s finding, based on responses to the RFI, that there are widely accepted commercial definitions of resellers and VARs is significant. The finding supports/confirms FAS needs an evaluation approach that distinguishes between the reseller’s and the VAR’s value/price to the customer. Second, FAS’s finding that value is in the service and not the markup sets the table for an evaluation approach that identifies and assesses the value of functions and/or services performed by a reseller or a VAR as part of the overall cost. What is not clear is whether FAS recognizes that the resellers, VARs, and distributors also perform value added services on behalf of Original Equipment Manufacturers (OEMs). These valued added services for the OEMs are reflected in the commercial pricing and support agreements/arrangements with their resellers, VARs, and distributors. It is a complex, dynamic market.
Third, and most thought provoking, are the insights under the “Recommended Pricing and Evaluation Framework.” FAS makes it clear that it will pursue an evaluation methodology that assesses the value of the services performed by a VAR as part of the overall contract cost and performance. FAS also states that “evaluation frameworks should encourage line-item pricing for complex requirements to clearly separate product resale from value-added services.” This statement raises a host of questions for stakeholders across the procurement community. How does an approach that breaks out individual line-item pricing and cost elements promote firm-fixed pricing at the order level? How does it support firm-fixed price, outcome-based solutions at the order level? Does this approach add another layer of complexity that undermines access to the commercial market? Is GSA solely focusing on the internal, commercial processes of OEMs, VARs, and resellers while ignoring how commercial customers structure their purchases? What value is there in breaking down price and cost elements of commercial items and services when government and commercial customers do not buy that way?
Fourth, as FAS notes, government work is more costly. To the extent FAS takes a price evaluation approach that assesses the value-added services, how will FAS account for the higher costs in determining what is fair and reasonable?
Finally, the Summary outlines the way forward, stating:
Based on this industry feedback, FAS has identified opportunities to strengthen its pricing practices through solicitation enhancements, workforce training, and additional resources for agency buyers. These actions will allow VARs to clearly communicate the value of their offerings while aligning with commercial practices and minimizing administrative burden.
Transparency and an opportunity for stakeholders to comment on any draft solicitation provisions and training materials will be important. FAS is to be commended for issuing the original RFI to the public in January. To the extent significant new terms or evaluation criteria are contemplated, those impacted by the new terms should have an opportunity to provide feedback on the proposed language. Transparency can only serve to improve the process, and ultimately, the final solicitation language enabling GSA to provide the Federal government with access to the full extent of existing commercial products and services for agencies to achieve their missions.
In Memory of Paul Joseph Caggiano
The Coalition for Common Sense in Government Procurement is deeply saddened by the passing of former Coalition President Paul Joseph Caggiano, who passed away peacefully on June 10.
Paul’s impact on the Coalition, the federal procurement community, and the countless individuals he mentored throughout his career cannot be overstated. For more than two decades, Paul served as President of the Coalition, helping to establish the organization as a trusted voice for common-sense procurement policies. Through his leadership, the Coalition built a strong reputation for advancing commercial acquisition practices and strengthening collaboration between government and industry, a legacy that continues to guide the organization today. The Coalition is grateful for Paul’s enduring commitment to the organization and its mission.
Born in Washington, D.C., on August 8, 1936, Paul graduated from Gonzaga High School and Mount Saint Mary’s College, where he earned a degree in Economics. He later pursued graduate studies at American University and served honorably in the Army National Guard, attaining the rank of Sergeant in the U.S. Army Reserve.
Paul’s distinguished career in federal procurement began in government service. In 1972, he joined the General Services Administration’s Federal Supply Service, where he eventually became Assistant Commissioner for Contracts. In 1982, Paul joined Washington Management Group (WMG), where he would serve as President and later Chairman of the Board.
Outside of his professional life, Paul was a devoted husband, father, grandfather, mentor, and friend whose integrity and generosity left a lasting impression on everyone he met. Throughout his life, Paul was known for his ability to offer thoughtful guidance and make others feel valued.
Funeral arrangements are being managed by Fellows, Helfenbein & Newnam Funeral Homes in Centreville, Maryland. A graveside service will be held at Chesterfield Cemetery in Centreville, Maryland, at 11:00 AM on Friday, August 7.
For more information, please visit here.
Senate Advances FY 2027 NDAA
MeriTalk reports that on June 12, the Senate Armed Services Committee voted to advance its version of the Fiscal Year (FY) 2027 National Defense Authorization Act (NDAA) to the Senate floor. Earlier this month, the House Armed Services Committee approved its version of the legislation. Both bills would authorize approximately $1.15 trillion for national defense and include acquisition reforms, cybersecurity initiatives, and a military pay raise.
The legislation generally aligns with the president’s budget request but does not include the proposed $350 billion in additional defense spending being considered through the budget reconciliation process. The House and Senate versions differ on military pay, with the House proposing a five to seven percent increase and the Senate authorizing a 3.6 percent increase.
The Senate bill would eliminate the Space Development Agency and the Space Rapid Capabilities Office and transfer their responsibilities into a new acquisition framework. It would also establish a new command for autonomous systems and create an Under Secretary for Cyber and Information Technology. Additional provisions address artificial intelligence (AI), quantum computing, counter-drone capabilities, Risk Management Framework (RMF) modernization, grants to help small businesses meet Cybersecurity Maturity Model Certification (CMMC) Level 2 requirements, and a U.S.-Israel technology cooperation initiative.
Coalition Launches MMAPP Working Group
The Coalition for Common Sense in Government Procurement (Coalition) is establishing a member working group focusing on the Management of Multiple Award Schedule (MAS) Acquisition Processes and Procedures (MMAPP).
The MMAPP working group will concentrate on the management of MAS offers, modifications, economic price adjustments, and cancellations. Based on member feedback to date, the attached outline of topic areas and questions sets the initial framework for examination.
Operational transparency, consistency, and the exercise of discretion in decision making are all subject areas for the working group. The working group will also address MAS systems that engage with customer agencies and contractors, including the Federal Acquisition Service (FAS) Catalog Platform (FCP).
The goal of the working group is to develop recommendations for the MAS program that will foster greater greater transparency regarding decision making rationale/criteria, increase consistency in operations, and promote sound exercise of discretion.
The attached is a living document and will be periodically updated with additional feedback/questions from the working group members. Please reach out to Joseph Snyderwine at jsnyderwine@thecgp.org to join the working group.
GSA Releases Preliminary Findings on Value Added Resellers
The General Services Administration (GSA) has released preliminary findings from its January 2026 Request for Information (RFI) on the role of Value-Added Resellers (VARs) under Special Item Number (SIN) 33411. GSA received 136 responses from industry stakeholders. GSA highlighted four key insights from the responses:
- GSA was informed of widely accepted commercial definitions for Resellers and VARs.
- Suggested Reseller Definition: “a company that is authorized by an original equipment manufacturer (OEM) to act as an intermediary, primarily focusing on the transaction and delivery of products to end-user customers.”
- Suggested VAR Definition: “a type of reseller that, in addition to selling the Original Equipment Manufacturer (OEM)’s product, also provides services from which the end-user customer directly benefits, such as configuration, licensing, integration, or professional support.”
- GSA learned the value of VARs lies in services they provide, including labor, technical expertise, risk mitigation, complex multi-vendor integration, security hardening, supply chain assurance, and compliance management.
- GSA noted that pricing frameworks should move away from percentage markups, that the agency should encourage line-item pricing, and that industry consensus opposes mandatory disclosures of markup percentages.
- Finally, GSA acknowledged that government work is inherently more expensive due to various non-commercial compliance and contracting costs.
Based on the feedback received, GSA stated that FAS will explore solicitation enhancements, workforce training, and additional resources for agency buyers. The agency expects to share additional details, including any potential updates to the MAS solicitation, through GSA Interact in the coming months. The Coalition submitted comments in response to the RFI, which may be found here.
Meet the First Service Dog Funded by Our Annual Golf Tournament!
Last year, something remarkable happened at the Coalition’s Annual Joseph P. Caggiano Memorial Charity Golf Tournament. Thanks to the generosity of our members, sponsors, and attendees, we raised enough funds to fully support the training and placement of a service dog for a veteran through Paws for Purple Hearts.
Today, we’re excited to introduce Waldron, the service dog your support helped make possible.
As a way of recognizing the Coalition’s contribution, Paws for Purple Hearts surprised us by naming the dog “Waldron” after Coalition President Roger Waldron. Recently celebrating his first birthday, Waldron has quickly become known for his larger-than-life personality and playful spirit.
One day, Waldron will be paired with a veteran whose life will be forever changed by the companionship, support, and assistance a highly trained service dog can provide. That impact was made possible because of the support of our Coalition community.
Want to meet Waldron in person? He’ll be joining us at this year’s tournament!
Registration is now open for the 13th Annual Joseph P. Caggiano Memorial Charity Golf Tournament on August 19, 2026, at Whiskey Creek Golf Club in Ijamsville, Maryland. The tournament brings together the government contracting community and friends of the Coalition for a day of golf, networking, and friendly competition, all while supporting causes that make a meaningful difference in the lives of veterans.
Join us as we celebrate Waldron’s journey and help support the training of future service dogs for veterans in need.
The tournament also supports The Coalition 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.
You can register a foursome, as an individual golfer, or to enjoy the scenic views from the veranda club here.
Secure Your Sponsorship for the Annual Golf Tournament!
We’re proud to offer a variety of sponsorship opportunities for the Joseph P. Caggiano Memorial Golf Tournament designed to fit every business and budget. Many sponsorship packages include golfer registrations, providing a unique opportunity to support two outstanding veteran-focused causes, increase your company’s visibility within the federal procurement community, and enjoy a day of networking and golf at one of the region’s most scenic courses.
This year’s sponsorship lineup includes several new opportunities, such as Golf Ball Sponsor, Golf Towel Sponsor, Driving Range Sponsor, and Putting Green Sponsor, alongside returning favorites like Beverage Cart Sponsor, Longest Drive/Closest to the Pin Sponsor, and Hole Sponsor.
Whether you’re looking for prominent event visibility, meaningful engagement with attendees, or a way to give back to our veteran community, there is a sponsorship opportunity to meet your goals.
View the sponsorship opportunities here.
If you have any questions, or are ready to secure your sponsorship for the annual golf tournament, please contact Heather Tarpley at htarpley@thecgp.org.
Thank you to our current sponsors!
Updated GSAR AI Clause Released for Public Comment
GSA has published a formal notice seeking public comment on a proposed General Services Administration Acquisition Regulation (GSAR) clause addressing the basic safeguarding of government data within Large Language Model (LLM) AI systems.
GSA will host a public listening session on July 14, 2026, from 11:00 AM to 2:00 PM (ET) at The George Washington Law School. Registration closes on July 3, 2026. The Coalition plans to participate in the listening session and is seeking member feedback to help inform our comments. Members are encouraged to submit feedback for the listening session to Kenneth Dodds at kdodds@thecgp.org by June 26.
Final comments to GSA on the proposed rule are due August 3, 2026. Please submit your comments and questions to kdodds@thecgp.org.
Key changes in the revised draft include:
- The clause has been renamed and revised to clarify that it applies only when LLMs process government data. The draft also establishes an “Applicability and Flowdown” section that identifies when the clause applies and outlines subcontractor flowdown requirements.
- The draft clarifies definitions related to government data, data inputs and outputs, contractors, and introduces new definitions for key participants in the LLM ecosystem, including developers, operators, integrators, and service providers.
- The clause provides additional guidance regarding contractor responsibilities, government data handling, licensing, compliance obligations, reporting requirements, and documentation timeframes.
- The draft replaces the term “change management” with “change notification” and provides additional guidance regarding when and how contractors must notify GSA of changes to an LLM system.
- The revised draft includes further information regarding the application of unbiased AI principles.
To read the Coalition’s feedback on the previous draft clause, click here.
SBA Launches Review of EDWOSBs
Federal News Network reports that the Small Business Administration (SBA) has launched a review of the Economically Disadvantaged Women-Owned Small Business (EDWOSB) program, requiring participating firms to submit personal and business tax returns for the past three years, along with responses to a 38-question survey.
The review follows a similar effort undertaken by SBA in December 2025 for participants in the 8(a) Business Development Program. That review ultimately resulted in the suspension of more than 1,100 firms and the termination of 154 companies from the program.
According to SBA, the review is intended to verify that participating firms continue to meet the economic disadvantage requirements of the EDWOSB program. If SBA determines that a firm remains eligible, it will provide written notice of continued certification. If SBA determines that a firm no longer meets program requirements, the agency may propose the firm’s decertification in accordance with 13 CFR 127.405.
The review comes as the Women-Owned Small Business program continues to grow. Although agencies have not met the governmentwide statutory goal of awarding five percent of federal contracting dollars to women-owned small businesses in recent years, contract awards to these firms have increased over time.
TMF Resumes Awards Amid Reauthorization Uncertainty
MeriTalk reports that the Technology Modernization Fund (TMF) has resumed accepting proposals, with just over $200 million available, but its future depends on congressional reauthorization before its authority expires on September 30. Acting Executive Director Jessie Posilkin said the fund cannot evaluate proposals after that date without action from Congress.
Created in 2017, the TMF funds agency modernization projects that are repaid over time. Posilkin said the fund has delivered about $12 billion in savings and that agencies are repaying on time. She also noted proposals remain highly competitive and said TMF is working with GSA, the Office of Management and Budget (OMB), and other agencies on new proposal opportunities. To support agencies in developing successful proposals, TMF has established cohorts that allow agencies to share best practices, discuss challenges, and learn from one another’s modernization efforts. According to Posilkin, the cohorts meet monthly and participate in quarterly reporting sessions focused on collaboration and problem-solving.
GSA Updates MAS Pricing Algorithm Under Pricing 2.0
GSA has implemented Pricing 2.0, a refinement to its MAS pricing algorithm intended to address outlier pricing and modify how market thresholds are calculated. According to GSA, this change is intended to better align government pricing benchmarks with commercial market rates.
Key Changes from the Existing Model:
- Commercial Price Anchor: The Market Baseline is now capped at the lower of the current model’s formula or the minimum observed commercial price, excluding outliers. This is intended to ensure that government baseline pricing cannot drift above the best commercial rates while preserving the analytical rigor of GSA’s existing methodology.
- Adjusted Price-Proportional Premium: The price-proportional premium will be reduced by 50 percent from current levels. Refining this premium reduces excessive price variability for identical items, protecting taxpayers from outlier pricing while maintaining fair profit opportunities for quality contractors.
The following sources are used to collect pricing data, which are refreshed every two months on a rolling 12-month basis:
- Government contract prices from GSA Advantage, FedMall, and NASA SEWP.
- Government order prices from MAS Transactional Data Reporting (TDR).
- Commercial catalog prices.
Pricing 2.0 took effect on June 5, 2026, and was implemented automatically without any required action from contractors.
GSA Expands Access to Governmentwide AI Evaluation Platform
MeriTalk reports that GSA plans to expand its USAi AI evaluation platform to 16 additional federal agencies by the end of 2026. More than 25 agencies already use USAi as a secure, shared environment to test and evaluate generative AI tools before fully implementing them. The platform is designed to help agencies move AI initiatives beyond the pilot stage and into operational use.
USAi is currently available to federal agencies at no cost, but beginning in fiscal year 2027, GSA plans to transition the platform to a cost-recovery model as demand for centralized AI testing and evaluation services continues to grow.
New Memo Centralizes Oversight of National Security Cybersecurity
Federal News Network reports that a national security presidential memorandum signed last week aims to strengthen the cybersecurity of sensitive government systems by centralizing oversight and accelerating efforts to secure those systems. The memo re-establishes and updates the Committee on National Security Systems (CNSS), an interagency body responsible for setting cybersecurity policies for military, intelligence, and other national security systems. Under the memorandum, the CNSS will establish baseline cybersecurity requirements for these systems.
The memo also formalizes the role of the Director of the National Security Agency as the national manager for national security systems, with authority to identify emerging threats and issue emergency directives to address cybersecurity risks. Additionally, the CNSS is directed to publish an initial roadmap for strengthening the cyber defense of national security systems within 60 days. The committee must also recommend updates to cyber incident reporting requirements, review and revise existing cybersecurity policies, and develop guidance for securely hosting national security systems in cloud environments.
DoW CIO Highlights Technology Transformation
MeriTalk reports that on June 12, Department of War Chief Information Officer Kristen Davies said the department is pursuing a major transformation of its technology enterprise to speed delivery of capabilities to warfighters. She emphasized reducing barriers, cutting bureaucracy, and accelerating innovation while addressing legacy systems and technology debt, including outdated infrastructure and unsupported software.
Davies also highlighted workforce efforts, stating that the department is expanding skills-based hiring practices, accelerating recruiting timelines, and launching a new Cyber Registered Apprenticeship Program (Cyber RAP) to help develop the next generation of cybersecurity professionals.
VA OIG Calls for Greater Oversight of Generative AI Tools
The Department of Veterans Affairs (VA) VA Office of Inspector General (OIG) recently released a report examining the VA’s use of generative AI tools in clinical care and documentation. According to the report, the VA provides clinical staff access to two general-purpose AI chat tools, VA GPT and Microsoft 365 Copilot Chat, which are frequently used to draft clinical notes and summarize patient information.
The OIG found that the VA had not designated these tools as high-impact AI systems and therefore had not applied the same safeguards required for other AI tools used in clinical settings, such as Ambient AI Scribe. As a result, the tools were not subject to requirements such as pre-deployment testing, human oversight, or other risk management measures. The report also found limited coordination with the VA’s National Center for Patient Safety and noted that the VA lacked an AI-specific reporting mechanism to identify patient safety events related to AI-generated documentation.
The OIG made three recommendations to strengthen oversight of generative AI chat tools:
- Review current use of generative AI chat tools, define permissible clinical uses, establish oversight responsibilities, and develop a risk mitigation and implementation plan.
- Evaluate whether safeguards applied to other high-impact AI tools, such as Ambient AI Scribe, should also apply to generative AI chat tools used in clinical care and documentation.
- Integrate AI-related risk monitoring into existing patient safety programs and ensure staff are trained to identify and report AI-related safety events.
The VA Under Secretary for Health concurred with the recommendations and outlined plans to develop additional guidance, quality assurance processes, educational resources, and updates to patient safety reporting systems.
Legal Corner – New DFARS Proposed Rule: What Defense Contractors Need to Know About Foreign Ownership, Control, or Influence (FOCI) Reporting Requirements
Authored by Anne Bluth Perry, Nikole Snyder, and Robert Mobley; Sheppard
On May 7, 2026, the Department of Defense (“DoD”) issued a new proposed rule—Defense Federal Acquisition Regulation Supplement: Mitigating Risks Related to Foreign Ownership, Control, or Influence (“DFARS Case 2021-D011”)—seeking to amend the DFARS to mitigate risks related to beneficial ownership or foreign ownership, control, or influence (“FOCI”) (the “Proposed Rule”). For defense contractors and subcontractors, the Proposed Rule further implements disclosure obligations, eligibility requirements, and contract performance responsibilities relating to all manner of foreign investment.
New Requirements:
The Proposed Rule introduces a series of structural changes to the DFARS regulatory framework that will directly affect “covered” contractors and subcontractors. “Covered” contractors and subcontractors are “existing or prospective contractors or subcontractors, at any tier, of the DoD with a contract or subcontract valued above $5 million.” By introducing this rule, DoD aims to amend the DFARS by creating Part 240, Information Security and Supply Chain Security, within which DoD proposes to create section 240.27X, Mitigation of Risks Related to Beneficial Ownership or Foreign Ownership, Control, or Influence.[1]
Solicitation Provision
The Proposed Rule will require a new solicitation provision, DFARS 252.240-70XX, Disclosure of Beneficial Ownership or Foreign Ownership, Control, or Influence — Representation, which will require offerors to complete a Standard Form (“SF”) 328, Certificate Pertaining to Foreign Interests, and provide supporting documents for Defense Counterintelligence and Security Agency (“DCSA”) review in the National Industrial Security System (“NISS”). These obligations had typically been confined to contractors seeking or holding a facility clearance. Now, such obligations have been expanded to capture all contractors who currently possess or are competing for a contract or subcontract above $5 million—and in some circumstances, even includes contractors selling purely commercial products and services. This provision also puts offerors on notice that if the requiring activity determines, based on input from DCSA, that FOCI or beneficial ownership poses a risk or potential risk of compromise to national security that may be mitigated, the offeror must agree at the time of award to implement a risk mitigation strategy within 90 days of award. By submitting its offer, the offeror must represent that it has submitted the SF 328 and the contact information of each beneficial owner[2] in NISS, and that the information is current, accurate, and complete.
Contract Clause
Additionally, a new contract clause, DFARS 252.240-70YY, Disclosure of Beneficial Ownership or Foreign Ownership, Control, or Influence, requires contractors to: (1) disclose to DCSA their beneficial ownership and whether they are under FOCI by submitting an updated SF 328 in NISS; and (2) update the SF 328 and supporting documents, including the contact information of each beneficial owner in NISS.
The clause further imposes important downstream obligations:
- Contractors must implement risk mitigation strategies within 90 calendar days of contract award, option exercise, modification, or the identification of risks during contract performance.
- Contractors must ensure all subcontractors awarded subcontracts exceeding $5 million have an eligible status in NISS prior to subcontract award and maintain that eligible status for the duration of subcontract performance.
- If the contractor has any changes in FOCI or beneficial ownership during performance of the contract, or if the contractor is notified of such by a subcontractor at any tier or supplier, the contractor must report the changes by submitting an updated SF 328 in NISS.
DFARS 252.240-70YY also establishes tight timeframes for mid-performance reporting:
- Within 3 business days from the date of identification or notification of a change that may place the contractor or subcontractor under FOCI, the contractor must report the foreign owner’s or beneficial owner’s name, relevant information about that person, and any readily available information about risk mitigation actions undertaken or recommended.
- Within 10 business days of being notified by DCSA that FOCI or beneficial ownership poses a risk or potential risk of compromise to national security, the contractor must initiate a plan of action to implement DCSA’s recommendations, submit additional information, describe any risk mitigation efforts undertaken to date, and confirm in NISS that it will comply with the identified risk mitigation recommendations.
The new procedures direct government contracting officers not to award or modify a contract, or exercise an option unless the offeror or contractor has a status of eligible in the NISS, available at https://niss.dcsa.mil/.
Practical Impacts:
For those contractors who hold facility clearances, the requirement to complete and update the SF 328 already generally applies. But for contractors who have not sought or obtained a facility clearance, this will likely be a new process, and one that is fairly complicated.
Of course, there are aspects of the Proposed Rule that seem to exceed the existing obligations even on companies with facility clearances. For example, under the Proposed Rule, contractors are required to update the SF 328 when there are “any changes in FOCI or beneficial ownership” and must certify that the SF 328 is “current, accurate, and complete” on the date proposals are submitted. There is no limitation on what constitutes a “change” that must be reported. For example, it is not limited to “material” changes.
Further, for companies not currently under FOCI mitigation, the risk mitigation strategies have to be implemented within 90 days of contract award, contract modification, or option exercise. Typically, such risk mitigation plans are proposed by contractors and approved by DCSA in advance of implementation. This process often takes multiple months itself, so it is unclear whether contractors can comply with the 90-day obligation, unless DCSA approval of the risk mitigation plan is quickly forthcoming upon the identification of FOCI—a timeline and internal government process over which contractors have no control.
Commercial Products and Services Providers
The Proposed Rule does not automatically apply to commercial products and services, unless the designated senior DoD official[3] determines that the contract involves a risk or potential risk to national security or potential compromise because of sensitive data, systems, or processes. However, contractors should not read this exemption as a safe harbor as it is currently unknown what criteria will be used to determine whether the contract involves a risk or potential risk to national security because of sensitive data, systems, or processes.
Flowdown Requirements
Finally, prime contractors must insert the substance of the new clause, including the flow-down obligation itself, in subcontracts and other contractual instruments that exceed $5 million. This means prime contractors will bear responsibility for ensuring that their entire supply chain is compliant, representing a significant new supply chain management burden and one that could cause significant performance delays.
Timeline of Changes:
| Milestone | Date / Timeframe |
| Proposed Rule Published in Federal Register | May 7, 2026 |
| Public Comment Period Closes | July 6, 2026 [4] |
| Final Rule (anticipated) | To be determined following public comment review |
Key Takeaways for Defense Contractors:
Entities that hold or intend to pursue DoD contracts valued above $5 million should begin assessing NISS eligibility status, reviewing beneficial ownership and FOCI disclosure posture, and evaluating their supply chain for subcontractor compliance obligations. Engaging experienced government contracts counsel during the comment period is also advisable to ensure your organization’s interests are properly represented.
*Robert Mobley is a law clerk in the firm’s Washington, D.C. office.
FOOTNOTES
[1] This will implement paragraphs (b)(2)(A), (b)(2)(C), and (c)(1) of section 847 of the NDAA for FY 2020, paragraph (c)(2) of section 819 of the NDAA for FY 2021, and elements of DoD Instruction 5205.87.
[2] “Beneficial Owner” is defined in 17 C.F.R. 240.13d-3, and includes “any person who, directly or indirectly, through any contract, arrangement, understanding, relationship, or otherwise has or shares: (1) Voting power which includes the power to vote, or to direct the voting of, such security; and/or, (2) Investment power which includes the power to dispose, or to direct the disposition of, such security.”
[3] The Proposed Rule states, “The term ‘designated senior DoD official’ is used in this proposed rule as a placeholder.”
[4] Comments on the proposed rule must be submitted in writing on or before July 6, 2026, to be considered in the formation of a final rule.
GSA to Host Small Business Contracting Opportunities Forum
GSA will host the FY26 Category Management Small Business Contracting Opportunities Forum on July 8. The forum will bring together federal stakeholders, industry leaders, prime contractors, and small businesses to discuss opportunities, resources, and strategies for success in the federal marketplace.
Topics will include identifying government contracting opportunities, leveraging available resources and programs, marketing GSA contracts, exploring teaming and subcontracting opportunities, and navigating the government contracting landscape.
The event will take place from 8:30 AM – 3:00 PM (ET) at National Industries for the Blind in Alexandria, Virginia. Additional information and registration details are available here.
Latest MAS Developments, Compliance Updates & Best Practice, June 23
Please join us for a virtual all-member meeting hosted by IT/Services Committee on June 23 from 10:00 -11:00 AM (ET). The Gormley Group’s Sean Nulty, Managing Principal Consultant, and Andrew Sisti, Principal GSA Schedule Consultant and GSA Systems Subject Matter Expert, will provide an update on the latest developments and trends within GSA’s Multiple Award Schedule (MAS) program, including the following topics:
- Know Your Contract Terms and Conditions
- Compliance Essentials for Maintaining MAS Contract
- Best Practices for Navigating GSA
- Impact of Recent Changes on the MAS Program
The meeting will take place virtually.
To register, click here. Note: This is a members-only event. If you see a message that says “Registration Not Available” please log in using your member account.
VA Acquisition Briefing with GAO, July 8
Please join us for a Healthcare Committee meeting on July 8 at 11:00 AM ET for a discussion on VA acquisition featuring Tatiana Winger, Director of GAO’s Contracting and National Security Acquisitions team, and her colleagues. The meeting will be held virtually.
Since 2019, the Government Accountability Office (GAO) has included VA Acquisition Management on its High-Risk List due to recurring challenges identified through its oversight and review efforts. During the meeting, GAO representatives will share insights into the VA’s ongoing acquisition reorganization and discuss findings from their recent work, including:
- Opportunities and challenges associated with the VA’s acquisition reorganization.
- Recent GAO findings and recommendations related to VA’s procurement of common goods and services.
- GAO’s assessment of VA’s management and maintenance of high-tech medical equipment.
- Acquisition issues affecting the VA and the broader healthcare contracting community.
To register, click here. For any assistance with registration, please contact Mady Whiting at mady.whiting@thecgp.org.
The Department of War’s Use of OTAs, July 21
Please join us for an all-member briefing on July 21 at 11:00 AM ET for a discussion on OTAs featuring Tatiana Winger, Director of GAO’s Contracting and National Security Acquisitions team, and her colleagues. The meeting will be held virtually.
The Government Accountability Office (GAO) reviews federal programs on behalf of Congress. GAO has conducted work looking into federal agencies’ use of other transaction agreements (OTAs), which are a type of contracting mechanism not subject to the Federal Acquisition Regulations (FAR). In recent years, OTAs have grown in use and importance in light of actions taken by the Executive Branch and Congress. In this webinar, Tatiana Winger and several of her colleagues from GAO’s Contracting and National Security Acquisitions team will provide an overview of OTAs and discuss the findings from their most recent report looking into DOD’s use of OTAs opportunities. This will include a discussion of recent data trends and insights into how programs are using OTAs to quickly deliver capability to the warfighter.
To register, click here. For any assistance with registration, please contact Mady Whiting at mady.whiting@thecgp.org.