Thank You to Our Golf Tournament Sponsors!
One of the Coalition’s favorite annual traditions is almost here! The Joseph P. Caggiano Memorial Golf Tournament returns to Whiskey Creek Golf Club on August 19, which brings together the Federal contracting community for a day of friendly competition and networking in honor of our friend and colleague, Joe Caggiano.
As we count down to this year’s tournament, we want to extend our heartfelt thanks to our 2026 tournament sponsors. We are incredibly grateful for their generosity and support in making this year’s tournament one of our strongest yet. Their sponsorship helps create a memorable day for everyone on the course and allows us the ability to contribute to two meaningful programs that support veterans: Paws for Purple Hearts and the Coalition’s Endowed Scholarship Fund at The George Washington University Law School. Thanks to their partnership, the tournament continues to honor Joe Caggiano’s legacy while giving back to veterans through education, service, and lasting support.
Thank you to our sponsors!
Senate Introduces CR to Fund Government through Dec 11
On August 2, the Senate Appropriations Committee announced a bipartisan continuing resolution (CR) that funds the government through December 11, 2026. The CR also extends certain authorities like the Technology Modernization Fund (TMF), the Cybersecurity Information Sharing Act of 2015 (CISA 2015), and the Federal Cybersecurity Enhancement Act.
The draft CR would largely maintain current government funding levels through December 11 and extend Federal technology and cybersecurity authorizations past the fiscal year. The House passed its own CR on July 21 which would temporarily fund the government through December 4. Both House and Senate Appropriations Committees are seeking to avoid a potential government shutdown before November’s midterm elections. FY 2026 funding for the government expires on September 30, 2026.
Pentagon Issues IT Category Management Directive
DefenseScoop reports that Department of War (DoW) CIO Kirsten Davies approved a department-wide directive on IT category management (ITCM) on July 23. The directive is intended to streamline IT procurement, increase use of enterprise agreements, and reduce duplicative spending within the DoW.
Key provisions include:
- Increased use of best-in-class purchasing solutions and enterprise capabilities
- Greater reliance on core enterprise technology agreements, enterprise software agreements (ESAs), and joint enterprise licensing agreements
- Efforts to standardize and consolidate IT assets and configurations
- Expanded use of IT asset discovery and management automation tools
- Integration of cyber supply chain risk management into IT acquisition programs
The directive also establishes an ITCM Cross Functional Board and reinforces the role of the Enterprise Software Initiative (ESI) Working Group in driving enterprise IT purchasing, optimizing costs, and reducing unaligned spending across the department.
The ITCM directive is currently in effect as of July 29.
Scam Alert: Phishing Emails Impersonating GSA
GSA has issued a warning to contractors about an ongoing phishing campaign in which scammers are impersonating GSA officials using fake email addresses that closely resemble official @gsa.gov accounts. Reported scams include fraudulent requests for vendor credentialing fees and false compliance notices. Contractors should verify the sender’s email address, avoid sharing sensitive or payment information without confirmation, and report suspicious messages to their GSA Contracting Officer, the GSA OIG Hotline, or the FBI’s Internet Crime Complaint Center.
GSA Prohibition on the Use of Online Marketplaces for MAS Orders
On July 1, The Federal Acquisition Service issued a compliance reminder to Multiple Award Schedule contractors regarding the use of online marketplaces and third-party marketplaces in connection with MAS orders.
According to GSA, “the use of these platforms and marketplaces for MAS order fulfillment present a high risk of non-compliance and are, in most cases, inconsistent with MAS contract requirements unless the contractor can affirmatively demonstrate full compliance with all applicable MAS terms, ordering procedures, and supply-chain obligations.”
GSA noted that “MAS contractors remain the contractor of record and are responsible for ensuring that all MAS orders are accepted, processed, fulfilled, shipped, invoiced, reported, and performed in accordance with the contractor’s MAS contract, the applicable order, and governing MAS ordering procedures. This includes, but is not limited to, compliance with Trade Agreements Act requirements, Industrial Funding Fee reporting, product marking, pricing, product scope, invoicing, and supply-chain integrity requirements.”
This reminder applies regardless of the ordering channel used to place the MAS order, including eBuy, GSA Advantage, or other authorized MAS ordering methods. Contractors may not route MAS order fulfillment through online marketplaces or third-party marketplaces in a manner that conflicts with MAS contract requirements or applicable ordering procedures.
GSA issued a clarification that “This notice exclusively covers the use of non-MAS online marketplaces for MAS fulfillment. It does not pertain to agency use of the GSA Commercial Platforms Program, nor does it impact the vendor community’s ability to sell non-MAS items through online marketplaces.”
Coalition Submits Comments on Proposed GSA AI Clause
On Monday, the Coalition submitted comments in response to GSA’s proposed artificial intelligence (AI) clause (GSAR 552.239-7001, Basic Safeguarding of Data within Large Language Model Artificial Intelligence Systems). The final AI clause will be used in GSA’s Government-wide contracts, including the Multiple Award Schedule and OASIS+. The clause addresses issues specific to AI tools, including data safety, data ownership, intellectual property rights, output bias, and cyber incident reporting. The Coalition commends GSA for the opportunity to provide feedback on the clause particularly given the complex, cutting-edge nature of AI and AI contracting. We also provided feedback on various terms and conditions that may have a chilling effect on the use of AI by Federal agencies and contractors. Specifically, 26 recommendations were submitted to GSA to help align the AI clause with the Administration’s goal of more efficient and effective AI utilization by the Federal government. Thank you to all of our members who provided input for these comments.
GSA Releases MAS-TDR Guide
GSA has released its first edition of the MAS-TDR User Guide, a resource to help contractors navigate the program and meet reporting requirements. The guide is available for download on the “Help with TDR” page at GSA.gov. GSA plans to update it monthly based on industry feedback and program developments. Contractors are encouraged to check the webpage regularly for the latest version. To register for GSA MAS-TDR Office Hours, click here. Upcoming MAS-TDR Office Hours are:
- Aug 12, 2026 02:00 PM
- Sep 9, 2026 02:00 PM
- Oct 14, 2026 02:00 PM
- Nov 11, 2026 02:00 PM
- Dec 9, 2026 02:00 PM
MMAPS Working Group Identifies Focus Areas
The Coalition has established a new member working group focused on the GSA Management of Multiple Award Schedule (MAS) Acquisition Processes and Procedures (MMAPP).
The MMAPP Working Group will examine the management of GSA MAS offers, contract modifications, economic price adjustments, and contract cancellations. Based on member feedback the Coalition put together an outline of key MAS issues for the working group. The MMAP Working Group will be divided into the following groups:
- Pricing Models
- Systems
- Compliance
- Communications
- Services
Members interested in joining one of these subgroups should contact Joseph Snyderwine at JSnyderwine@thecgp.org.
DoW Hits Pause on CMMC: What Contractors Need to Know Now
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 Townsend L. Bourne, Sidney Howe; Sheppard
On July 13, 2026, the Department of War (“DoW”) dropped a major announcement regarding the Cybersecurity Maturity Model Certification (“CMMC”) program via a press release, Forging the Arsenal of Freedom: Department of War Suspends CMMC Phase II Requirements (the “Release”) (see our past blogs here and here for background on CMMC). The Release announced that DoW is immediately suspending the Phase II requirements for CMMC (originally scheduled to be effective November 10, 2026) as well as all pending and future CMMC implementation milestones across DoW solicitations/contracts. As a reminder, Phase II incorporated the Level 2 (C3PAO) requirement in applicable solicitations/contracts as a condition of award.
Review of CMMC
The Release further stated that DoW will begin a “comprehensive review of CMMC” with the goals of “aligning with Secretary of War Pete Hegseth’s Acquisition Transformation System (ATS) directives prioritizing speed to capability, lowering barriers for small, medium, and non-traditional businesses, and replacing bureaucratic compliance with scalable, resilient cybersecurity measures.” The Release continued to critique CMMC, stating that while the aim of the program was to enhance Defense Industrial Base (“DIB”) cybersecurity, instead, “it has created prohibitive compliance costs and bureaucratic burdens” citing Small Business Administration (“SBA”) data that “CMMC compliance is forcing innovative companies out of the [DIB] which will delay the delivery of critical capabilities to the warfighters.”
The DoW further announced and initiated a 60-day study of the “future” of the CMMC program. This includes a new CMMC Reform Task Force, reporting to the DoW Chief Information Officer (“CIO”), which will “conduct a comprehensive top-to-bottom review of the certification program.” The Task Force will serve as the central hub for industry feedback.
The DoW also published a Request for Information (“RFI”), Reforming CMMC and Reducing Compliance Burden for the Defense Industrial Base (DIB). The RFI “seeks direct feedback from DIB companies on practical strategies to inform the newly established CMMC Reform Task Force during its review.” Specifically, the RFI requests feedback on the following themes:
- Protecting federal data and uplifting operational resilience against cyber-attacks while also reducing compliance costs and administrative burdens; and
- Ideas such as DIB usage of existing commercial cybersecurity capabilities, leveraging and optimizing self-attestation capabilities, and streamlining cybersecurity compliance.
The RFI details seven specific questions for DIB feedback, in line with the above themes. All responses to the RFI are due by 12pm ET on Friday, August 14, 2026. Responses will be accepted via electronic means only to: whs.mc-alex.ad.mbx.eosd-psb-branch-mailbox@mail.mil and leanne.m.condren.civ@mail.mil.
DoW Memos
Along with the Release and RFI, the DoW published two memos: (1) Removing Barriers to Defense Industrial Base Expansion: Immediate Suspension and Strategic Review of Cybersecurity Maturity Model Certification Requirements (“CMMC Suspension Memo”), and (2) Implementing Department of War Chief Information Officer’s Suspension of the Advancement to Cybersecurity Maturity Model Certification Phase 2 Requirements (“CMMC Suspension Implementation Memo”).
The CMMC Suspension Memo emphasizes that the CMMC program is “structurally incompatible” with the DoW need to continue to “rapidly expand the DIB.” The Memo references SBA data that demonstrates that (1) prohibitive compliance costs, (2) severe shortages of C3PAO capacity, and (3) complex regulatory timelines are forcing small businesses and new businesses to opt out of DoW contracts subject to CMMC. The Memo directed three immediate actions: (1) suspension of the November 2026 Phase II transition deadline, as well as holding all pending and future CMMC deadlines in abeyance until further notice, (2) Task Force (detailed above) to conduct a 60-day review, with the goal to provide recommendations for a reformed framework, and (3) DoW shall continue to enforce baseline cybersecurity compliance (e.g., NIST SP 800-171 Rev. 2, DIB self-assessments and select government-led assessments, DFARS 252.204-7012).
The CMMC Suspension Implementation Memo articulates DoW implementation directives for the suspension of CMMC. The Memo specifies that DoW program offices/requiring activities are permitted only to include Level 1 (self) or Level 2 (self) requirements in contracts/solicitations. Further, program offices/requiring activities are directed to initiate amendments to active solicitations that include Level 2 (C3PAO) or Level 3 (DIBCAC) requirements. The amendment must explicitly remove these requirements and the contracting officer must issue a corresponding solicitation amendment as soon as practicable. For active contracts with these requirements, contracting officers must remove the requirements via modification “prior to the exercise of the next option period or during the next scheduled administrative modification.” Lastly, the CMMC waiver procedures are suspended pending the 60-day review of the program.
Current Status of CMMC
Note that the suspension has no effect on CMMC Phase I, which has been in effect since November 10, 2025. Phase I incorporated Level 1 (self) and Level 2 (self) requirements in applicable solicitations/contracts as a condition of award, as well as Level 2 (C3PAO) requirements at the DoW’s discretion.
Below is a summary table of the CMMC phases as well as the current status (as of July 13, 2026, pending DoW’s 60-day review) of each phase:
| Phase | Start Date | Impact | Status as ofJuly 13, 2026 |
| Phase 1 | November 10, 2025 | Inclusion of Level 1 (self) or Level 2 (self) requirement in applicable solicitations/contracts (as a condition of award), as well as Level 2 C3PAO certifications at DoW discretion | Effective |
| Phase 2 | One calendar year after Phase 1 begins. | Level 2 C3PAO requirement in applicable solicitations/contracts (as a condition of award). | Suspended |
| Phase 3 | One calendar year after Phase 2 begins. | Level 2 C3PAO as a condition for exercising option periods; and Level 3 (DIBCAC) requirement for all applicable solicitations/contracts (as a condition of award). | Suspended |
| Phase 4 | One calendar year after Phase 3 begins. | Full implementation of the CMMC requirements in all applicable solicitations and contracts, including option periods. | Suspended |
This is a major announcement that very likely means that CMMC as we know it will be changing. Contractors should continue to treat contractual requirements (including CMMC Level 1 (self) and Level 2 (self)) and baseline cybersecurity obligations as fully in force. It is also worth considering a submission in response to the RFI.
Sheppard’s Governmental Cybersecurity and Data Protection team is closely following the CMMC suspension and related developments and will continue to provide updates as they become available.
Healthcare Spotlight: DHA CPT Data Now Available to Members
The Coalition has received a new Defense Health Agency (DHA) data set covering Current Procedural Terminology (CPT) codes for medical services and procedures performed during calendar year 2025.
The data includes procedure volumes by CPT/HCPCS code and identifies whether services were performed through direct care at Military Treatment Facilities (MTFs) or through the contracted private-sector TRICARE network.
Note: The DHA data is provided in aggregate and does not identify individual Military Treatment Facilities.
Members can request a customized report by providing the CPT codes most relevant to their business. The report will show the 2025 procedure volumes for each requested code, broken out between direct care MTFs and the private-sector TRICARE network.
If you are interested in requesting a report or learning more, please contact Michael Hanafin at mhanafin@thecgp.org.
Thank You to Our Fall Training Conference Platinum Sponsors!
The Coalition extends its sincere thanks to our 2026 Fall Training Conference Platinum Sponsors for their support and leadership. Platinum Sponsors’ enhanced commitment helps make this event possible and strengthens opportunities for education and collaboration across the federal procurement community.
Be sure to stop by our Platinum Sponsor tabletops each day of the conference, where representatives will be available to answer questions and showcase their products and services.
We are equally grateful to every sponsor whose partnership contributes to the success of Fall Training Conference. Together, your support enables us to deliver a meaningful experience for our members, guests, and other industry stakeholders
This year’s conference on November 18–19, 2026 at the Fairview Park Marriott in Falls Church, Virginia will feature government decision-makers and industry experts who will discuss the latest developments in governmentwide and healthcare procurement. Attendees will learn about the policies, regulations, and acquisition trends impacting today’s federal marketplace.
Interested in becoming a sponsor? Sponsorship opportunities are still available and are currently being secured. Organizations interested in showcasing their brand and supporting this premier procurement event are encouraged to review the 2026 Fall Training Conference Sponsorship Prospectus to learn more about the available sponsorship packages.
Stay tuned for additional information on conference registration and our hotel room block, which will be announced in the coming weeks!
GSA’s OCAS Hosting Session for Small Businesses, August 26
The Coalition is sharing the following event announcement from GSA:
The U.S. General Services Administration’s Office of Centralized Acquisition Services (OCAS), in partnership with GSA’s Office of Small Business (OSB), is hosting an informative session on Wednesday, August 26, 2026, at 1 p.m. ET tailored specifically for our industry partners.
This session will provide a comprehensive look at how OCAS is streamlining governmentwide procurement and creating new opportunities for our industry partners.
Session Highlights:
- OSB Overview: GSA OSB priorities and resources for small business
- OCAS Overview: Learn about our mission and how we simplify the acquisition of common goods and services.
- Procurement Consolidation & Executive Order 14240: Understand the strategic initiatives shaping our procurement landscape.
- Engaging with OCAS: Discover how to effectively partner with us and navigate upcoming opportunities.
- Future Engagements: Get a preview of our upcoming events.
Event Details:
- Date: August 26, 2026
- Time: 1-2 p.m. ET
Virtual VA FSS Industry Day, August 26
The Coalition is pleased to announce that we are hosting a virtual VA Federal Supply Schedule (FSS) industry day on August 26 from 10 AM to 12:30 PM (ET).
The opening session will feature remarks from Sharon Chang, Director of the FSS program at the U.S. Department of Veterans Affairs on the program’s current organizational structure, initiatives and priorities. The industry day will also feature a sessions on updates to the FSS solicitation and breakout sessions on the specific Schedules for Medical/Surgical Equipment, Pharmaceutical, and Healthcare Services.
To register, click here. For any assistance with registration, please contact Mady Whiting at mady.whiting@thecgp.org
Note: This is a members-only event. If you see a message that says “Registration Not Available” please log in using your member account.
Proposed Changes for Small Businesses in the FY 2027 NDAA, August 27
Moshe Schwartz, President of Etherton and Associates, Inc., and the Coalition’s Defense Fellow, on August 27 from 12:00 – 1:00 PM (ET) will provide a webinar on the proposed small business provisions in the pending National Defense Authorization Act (NDAA) of 2027.
To register, click here. For any assistance with registration, please contact Mady Whiting at mady.whiting@thecgp.org