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Friday Flash 9/4/26

Far and Beyond Invest in Success: Join Us for the Coalition’s Inaugural Compliance Training Conference

The federal procurement landscape continues to present new challenges and opportunities for government contractors. Changes in acquisition policy, emerging technologies like artificial intelligence, shifting enforcement priorities, and new contractor responsibilities are creating new compliance considerations for companies doing business with the federal government.

Staying ahead of these developments is essential. Effective compliance programs help organizations identify and manage risk, support their employees, and maintain the trust that is fundamental to successful partnerships with Federal customers. To support the contracting community in navigating these challenges, the Coalition is pleased to launch Invest in Success: Coalition Compliance Training Conference, the first in a new series focused on compliance in the Federal marketplace.

The inaugural conference will take place on the morning of October 7 at CGI Federal in Arlington, Virginia, with virtual attendance also available. The event will bring together government, industry, and legal experts to provide practical insights into some of the most important compliance issues facing government contractors today.

Compliance in the Age of AI

Artificial intelligence is rapidly becoming part of the way both government and industry operate, creating new opportunities to improve efficiency and performance. At the same time, its growing use raises important questions about ethics, oversight, accountability, and compliance.

Jessica Tillipman, Associate Dean for Government Procurement Law Studies at The George Washington University Law School, will deliver the conference keynote, “Procurement in the Age of AI: Ethics & Compliance in a Changing Federal Marketplace.”

Jessica will examine emerging AI-related risks across the procurement lifecycle and supply chain, including organizational conflicts of interest, AI-enabled fraud and False Claims Act exposure, algorithmic collusion, system manipulation, and over-reliance on automated judgment. The session also will address practical considerations for contractors as AI becomes increasingly integrated into their organizations, subcontractors, and Federal procurement activities.

Strengthening Compliance Through Active Bystandership

Policies and procedures are important components of an effective compliance program, but an organization’s employees also play an important role in identifying and addressing potential issues before they become larger problems.

During “Active Bystandership: The Missing Link in Corporate Risk Reduction,” Jonathan Aronie, Partner at Sheppard, will introduce attendees to an approach designed to give employees the skills and confidence to intervene when they see a colleague moving toward a potential compliance issue.

Active Bystandership has already been applied in high-stakes environments including aviation, healthcare, law enforcement, and the military. The session will explore how government contractors can apply these principles to strengthen organizational culture and reduce compliance risk.

Perspectives on the Civil False Claims Act

Of course, any discussion of contractor compliance must include the Civil False Claims Act, which remains one of the most significant enforcement considerations for companies participating in the federal market.

Chris Terranova, Assistant Director, Civil Fraud Section, Commercial Litigation Branch, Department of Justice; Alex Canizares, Partner at Vinson & Elkins; Terra Fulham, Special Counsel at Covington; and Tirzah Lollar, Partner at Arnold & Porter, will provide perspectives on the False Claims Act and key compliance considerations for government contractors.

The discussion will provide attendees with an opportunity to hear perspectives from both government and the private sector on an area that continues to be critically important to the contracting community.

The Value of Compliance

Ultimately, compliance is an investment into an organization’s people, its reputation, its relationships with federal customers, and its ability to compete successfully in the government market. Our goal is to provide members of the procurement community with practical information and perspectives that they can take back to their organizations and put to use.

The October 7 conference also will provide an opportunity to connect with colleagues from across the procurement community. Those joining us in person at CGI Federal will have the added benefit of networking with fellow compliance, contracts, and legal professionals, as well as speakers and other leaders from government and industry.

We encourage members to share this important event with the professionals across their organizations responsible for contracts, compliance, ethics, legal risk, and Federal contracting requirements. We look forward to seeing you on October 7!

To register, click here.

Registration Now Open! 2026 Fall Training Conference

Registration is now open for the Coalition’s 2026 Fall Training Conference! Join us on November 18–19 at the Fairview Park Marriott in Falls Church, Virginia, for two days of timely discussions on the issues shaping the federal procurement landscape.

This year’s conference will once again bring together government and industry leaders to examine the latest developments in governmentwide and healthcare procurement. Attendees will hear directly from key government decision makers and industry experts while having the opportunity to connect with colleagues from across the procurement community.

Agenda Preview

Keynote Address – Post Election: What Happened, Where are We, and Where are We Going?
                                     

We are excited to welcome former Congressman and current Holland & Knight partner Tom Davis, who will deliver keynote remarks examining the 2026 election results. Tom will provide an in-depth analysis of the results and their far-reaching implications for the federal market and procurement policy.

Legislative & Budget Update
                                     

Coalition Defense Fellow and President of Etherton and Associates Moshe Schwartz will also return for his popular legislative and budget update. Moshe will break down the latest developments on Capitol Hill, including key legislative and funding issues, and discuss what government contractors should be watching as we head into 2027.

Additional agenda details will be announced in the coming weeks.

To register for the Fall Training Conference, click here.

Click here to Book your group rate for the Coalition’s Fall Training Conference at the Fairview Park Marriott.

Secure Your Sponsorship

Sponsorship opportunities are now 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 for additional information. If you have any questions or are ready to secure your sponsorship, please contact Heather Tarpley at htarpley@thecgp.org.

Thank you to our current sponsors


Government Funded Through December

Federal News Network reports that the House passed a short-term continuing resolution to fund the government through early December. This gives lawmakers time to focus on the midterm elections. “It gives the nation and our constituents certainty, certainty that the government will remain open, certainty that our service members will be paid,” said Rep. Tom Cole, the Republican chairman of the House Appropriations Committee.


Industry Recommendations for OneGov Transition

 NextGov reports that as agencies prepare for the expiration of discounted OneGov software deals, the Center for Procurement Advocacy published a white paper outlining recommendations for managing the transition. OneGov provides federal agencies with discounted access to software, including AI tools such as ChatGPT, by leveraging the government’s collective purchasing power. 

The white paper recommends that the Trump administration create a centralized inventory of OneGov offerings that includes expiration dates, expected price increases and participating agencies. It also calls for contractors to provide agencies with advance estimates of renewal and usage costs, and for agencies to identify successful AI deployments, assess their costs after discounts expire, and incorporate those expenses into FY2027 budget planning. The group also recommends giving agencies more flexibility to switch between AI platforms to reduce vendor lock-in.


Treasury CIO Appointed Director of TTS & Deputy Commissioner of FAS 

MeriTalk reports that Department of Treasury Chief Information Officer (CIO), Sam Corcos has been appointed acting director of Technology Transformation Services (TTS) and acting deputy commissioner of the Federal Acquisition Service (FAS). Mr. Corcos will also serve as acting assistant commissioner of Login.gov, the government’s single sign-on solution for federal websites. Mr. Corcos entered government work as part of the Department of Government Efficiency (DOGE). Before entering government work, he co-founded health tech company, Levels Health.


OMB Sets Out Two-Year Plan for Login.gov

Federal News Network reports that according to a new Office of Management and Budget (OMB) memo, that the Login.gov platform is to function as the single source for authentication and verification “whenever possible.” The memo provides two exemptions for public facing websites for organizations and individuals acting on behalf of another individual. Agencies have two years to deploy Login.gov or submit a notice to OMB. 


Army Makes SWP Mandatory for Development 

Meritalk reports that the Army has made the Software Acquisition Pathway (SWP) the mandatory route for software development efforts and has directed program managers to prioritize commercial solutions to acquire solutions faster. In a recently published memo, the Army Secretary outlined the new acquisition policy aimed at rapidly delivering resilient, adaptable, and secure software capabilities. The policy directs Army contracting officers to use enterprise software contracts to acquire commercial software that can be used more than once. Additionally, the policy instructs program managers to consider commercial solutions first, followed by configured commercial solutions. Finally, the policy provides that custom development should be “extremely rare and will be authorized only when no commercial solution can meet a significant portion of operational needs.” 


SBA Size Standards: Public Comments Requested

The Small Business Administration (SBA) has issued a proposed rule that would establish new size standards for 338 industry groups and industries. The proposed rule would significantly increase the number of businesses considered “small”.

SBA is seeking public comments on the proposed rule. Comments are due September 21, 2026. The Coalition is considering providing comments on this proposed rule. If you have input or feedback you would like the Coalition to provide to the government, please email said feedback to Greg Waldron at gwaldron@thecgp.org by the end of the day September 11. 

As part of the proposal, SBA would simplify its size standards by moving from nearly 1,000 individual standards based primarily on six-digit NAICS codes to 338 standards using a combination of four- and five-digit NAICS codes. SBA is also proposing to eliminate size standard exceptions and shift numerous industries from receipt-based to employee-based standards.


DoW Expands Access to Commercial AI Models on GenAI.mil

DefenseScoopreports that the Department of War (DoW) has expanded internal access to leading artificial intelligence (AI) tools by making Grok for government and ChatGPT.mil available on GenAI.mil.

The DoW established GenAI.mil in December of 2025 to serve as a centralized platform through which DoW employees may access AI tools. Starshield AI’s Grok for Government and OpenAI’s ChatGPT mil both achieved accreditation for use with Controlled Unclassified Information (CUI) at Impact Level 5 (IL5).  


VA Launches AI Helpdesk Chatbot

FedScoop reports that the Department of Veterans Affairs (VA) launched an AI-powered chatbot, currently in beta testing, to help Veterans find information about benefits and services. VA said the chatbot is designed to improve website navigation and help Veterans find relevant information more easily. Planned enhancements later this year include personalized experiences through sign-in, live agent support, and expansion to additional VA webpages. The agency said the chatbot does not collect personally identifiable information and is not intended for emergency or medical use. 


Off The Shelf: CMMC: To Be or Not to Be

Michael Gruden, partner at Steptoe LLP, joined Off the Shelf podcast to discuss the evolving cybersecurity compliance landscape for federal contractors. Gruden examines the status of DoW’s Cybersecurity Maturity Model Certification (CMMC), including the factors contributing to the current pause and his outlook for the program’s next steps. 

He also addresses key considerations for contractors navigating cyber compliance requirements, along with the potential impact of the Federal Acquisition Regulation Overhaul (RFO) and new proposed CUI provisions in FAR Part 40. The conversation concludes with a look at the ongoing rulemaking surrounding the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) and what contractors can expect.

Listen to the full episode here.


DOJ Launches the National Fraud Detection Center

By J. Ryan FrazeeJohn PrairieArun G. RaoFindley Penn-Hughes & Ravi Shah; Mayer Brown

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.

The Department of Justice (DOJ) has announced the launch of the National Fraud Detection Center (NFDC), a new prosecutor-led, multi-agency unit tasked with investigating those who defraud federal government programs. This initiative was previewed by an August 13, 2026 memorandum outlining the National Fraud Enforcement Division’s Enforcement Priorities (the McDonald Memo) (see our August 18 Legal Update), and is being led by Acting Assistant Director Amanda Riedel of the Executive Office for U.S. Attorneys (EOUSA) and Acting Chief Cody Matthew Herche of the Global Trade & Commerce Enforcement Section, formerly head of DOJ’s Trade Fraud Task Force (TFTF). The NFDC operates as part of President Trump’s Task Force to Eliminate Fraud, the whole-of-government initiative established by Executive Order 14395 and chaired by the Vice President, as outlined in our March 18 Legal Update.

The NFDC’s Purpose

The NFDC is designed to increase cross-program visibility. Individual agencies have historically tracked fraud within their own programs but sometimes had difficulty detecting schemes spanning multiple federal programs simultaneously. The NFDC seeks to address this shortcoming by embedding analysts from across the Inspector General community and leveraging shared technology to generate criminal leads that drive prosecutions.

The Center’s inaugural partners include the FBI, Homeland Security Investigations, IRS Criminal Investigation, FinCEN, the Treasury Department, the Pandemic Response Accountability Committee, and Inspectors General from the Departments of Agriculture, Education, Health and Human Services, Homeland Security, Housing and Urban Development, Interior, Labor, and Veterans Affairs, as well as the Defense Criminal Investigative Service, the Treasury Inspector General for Tax Administration, the Small Business Administration, and the Social Security Administration. State partners from Alabama, Florida, Georgia, Louisiana, Mississippi, Ohio, and South Carolina are also participating, providing access to investigators who can identify whether a federal suspect is appearing in state cases under a different company name or identity.

The NFDC’s Leadership Signals Seriousness of Purpose

The choice of NFDC’s leadership suggests that  the unit’s creation is not merely an administrative reshuffling. Riedel is an experienced federal prosecutor with a track record of standing up large-scale, cross-agency fraud initiatives. She previously served as Director of COVID-19 Fraud Enforcement during the Biden-Harris Administration and as White Collar Coordinator for the EOUSA. Herche brings recent experience helping to develop DOJ’s trade fraud enforcement effort, serving as the head of the interagency TFTF, which recently published a new benchmark Enforcement Resource Guide and announced $1 billion in civil and criminal recoveries, penalties, forfeitures, and publicly charged losses (see our July 21 Legal Update). Together, their appointments signal that the NFDC will combine traditional white collar prosecution expertise with the data-driven, multi-agency coordination model that has characterized recent efforts related to trade and pandemic fraud enforcement.

Why Federal Contractors, Grant Recipients, Financial Institutions, and Others Should Take Notice

The NFDC’s creation should be considered alongside the August 18 final rule that formally established the National Fraud Enforcement Division and conferred upon it jurisdiction over criminal fraud, criminal tax, trade and customs fraud, fraud involving monies owed to or paid by the United States, health plan fraud, and controlled substances offenses—all of which previously sat in separate DOJ components. For most of these categories the Fraud Division now shares authority with the Criminal Division; only criminal tax and health plan fraud are assigned to it exclusively. The Division’s stated mandate to use “advanced, data-driven investigative techniques,” paired with the NFDC’s multi-agency data sharing, means that DOJ is now connecting data across tax, trade, healthcare, and federal benefits programs in ways that many companies—including financial institutions—do not yet do internally.

For federal contractors and grant recipients, the implications are significant. The NFDC’s mandate specifically encompasses fraud involving monies owed to or paid by the United States—capturing procurement fraud, grant fraud, and benefits program fraud. The McDonald Memo explicitly identifies government procurement fraud (including bid rigging, defective pricing, self-dealing, bribery, and product substitution) and benefit and grant program fraud (including student loans, veterans’ benefits, disaster relief, and small business programs) as critical priorities. With a dedicated analytics operation now funneling fraud leads to a consolidated prosecution group, backed by FBI investigative resources and Inspectors General partnerships across virtually every major grant-making agency, contractors and grant recipients face a materially different enforcement landscape than previously existed. The NFDC’s state-level partnerships add another dimension, allowing DOJ to extend its reach through state investigators.

For banks and other financial institutions, these developments are particularly significant. Many institutions maintain separate compliance teams for BSA/AML, sanctions, tax reporting, trade finance, and healthcare lending or payments. These teams sometimes operate in silos with limited data integration. DOJ, through the NFDC, is seeking to build the capacity to detect patterns across these categories—identifying, for example, whether an entity flagged for suspicious trade activity is also drawing federal benefits or submitting questionable tax filings. Companies that are unable to replicate that cross-referencing internally may find themselves on the back foot when the NFDC generates an investigative lead that spans multiple regulatory domains.

Healthcare organizations, importers, and companies participating in federally funded relief or reimbursement programs should likewise take note. The NFDC’s approach means that conduct previously policed by a single agency—a billing irregularity flagged by the HHS-OIG, a customs discrepancy identified by U.S. Immigration and Customs Enforcement Homeland Security Investigations, or a tax anomaly detected by IRS-CI—can now be cross-referenced against other federal datasets, potentially revealing broader patterns of noncompliance that a single agency would have been unlikely to have identified on its own.

Next Steps and Client Considerations

  • Cross-functional compliance integration: Organizations should assess whether their compliance infrastructure allows them to connect data across business lines in the same way that DOJ now proposes to do across agencies, particularly tax, trade, government contracts, and health care.
  • Proactive data monitoring: The NFDC’s emphasis on analytics-driven lead generation means that DOJ may identify potential misconduct before a whistleblower report, voluntary self-disclosure, or traditional referral. Companies should consider whether their own monitoring capabilities allow them to identify and address issues before the government does.
  • Voluntary self-disclosure: The National Fraud Enforcement Division operates under the Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy announced in March 2026 (see our March 12 Legal Update). The NFDC’s enhanced detection capabilities make the calculus around self-disclosure more significant, as the window between misconduct and government detection may be narrowing.
  • Broader investigative scope: Under the August 18 final rule, the Fraud Division can prosecute any federal crime it discovers during an investigation in one of its enumerated areas. A lead generated by the NFDC in one program could expand into a multi-offense prosecution without the need for referral to another DOJ component.

VA Uploads Site on Restructure

The Department of Veterans Affairs has released a website on their restructure for impact & sustainability effort (RISE). The RISE website links to a video from VA Under Secretary for Health John Bartrum that covers the VHA RISE implementation timeline, what Initial Operating Capability (IOC) and Full Operating Capability (FOC) mean for staff and Veterans, and how VA will standardize health care delivery across all its facilities. Additionally, the site contains the new 5 VISN map, the 18 Health Service Area map, and lists both an organization chart and VISN leadership graph.


Webinar: Navigating OTAs & Other Non-Traditional Agreements, September 24

Please join the Coalition for a webinar with Covington & Burling on September 24 from 12:00PM – 1:00PM (ET), for a discussion of non-traditional procurement opportunities.

Special Counsel Peter Terenzio and Associate Daniel Raddenbach will discuss important updates to the authorities that govern alternatives to traditional FAR-covered agreements, including OTAs, grants, and cooperative agreements. These include changes to the scope of the Department of War’s OTA authority and a proposed full rewrite of the regulations that govern federal financial assistance.

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


GWAC/MAC Committee Meeting with GSA AAS, September 30  

The Coalition’s GWAC/MAC Committee will host a meeting on September 30, at 10:00 AM (ET). Pete Burr, Assistant Commissioner of GSA’s Office of Assisted Acquisition Services (AAS) will provide an update on AAS and its current priorities, followed by an opportunity for dialogue and discussion.  

The meeting will be held in person in the DMV area (location TBA). Virtual attendance will also be supported.  

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

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