FAR & Beyond: Blog:
A Time to Remember
History provides us with many “where-were-you-when” moments. Some represent joyous events, while others strike at our hearts and become defining moments in our personal history and in the history of our nation. Almost by definition, the impact of these events is not limited to one generation.
This year, our nation marks the 25th anniversary of September 11, 2001. On that day, terrorists took the lives of nearly 3,000 people and forever changed the lives of countless families, communities, and Americans across the country.
As we commemorate this significant anniversary, we believe it is appropriate to revisit the reflections shared by Coalition staff five years ago on the 20th anniversary of September 11. Their memories capture the uncertainty, fear, grief, and resolve experienced that day and remind us of the deeply personal impact of an event that changed our nation and the world.
– – I was 9, in DC, in gym class that was outdoors when very dark, almost black, clouds started rolling in the distance. What came next was what seemed like an eternity of uncertainty, fear, and confusion.
– – I remember racing into town from Northern Virginia to pick up my son who was in daycare at the FDIC—right next to the Old Executive Office Building and the White House Complex. I got there, grabbed my son, and was on my way out when my wife walked in after having run across the mall from her office to get to the FDIC. I had parked the minivan at the rear of the Department of Interior and was able to do a U-turn and head out 66 to home. An enduring memory was seeing the smoke rise from the Pentagon as we crossed the Roosevelt Bridge into Virginia.
– – Many people in my Long Island town worked in the financial district. Some were from my high school. I wondered about their fate and the impact on our small community. I learned that almost 50 people were taken that day. If there were a funeral per day at the cathedral, it would take over a month to bury our dead.
– – Deciding, after the first plane hit, that it was going to be a long day, and I better go get a glass of water, I opened the door and saw hundreds of staff literally running out of the Russell Senate Office Building. I remember being told by the Capitol Police, “get out of here.”
– – We lived on the 15th floor of a high-rise apartment building, less than a mile from the Pentagon. When the third plane hit, our entire building shook as if we were experiencing an earthquake. We had a direct line of sight to the Pentagon and could see the flames and smoke billowing for hours – a vision and experience I will never forget.
– – My brother worked just a few blocks from the towers, and as soon as everyone realized what was happening, I tried calling him over and over for hours, but the phone networks were down. His building had been evacuated, and they were literally told to run for their lives. He ran for several miles in his dress shoes and suit and was finally able to get a call to connect in the early afternoon letting us know he was okay.
– – The kids and I were walking into the house after racing home from school and daycare. My daughter asked, “Daddy, are people going to come to our house and get us?” At that moment, as if on cue, a military jet thundered across the sky. We all looked up. To calm her, I said, “Don’t worry, honey. Do you hear that jet? We have the best military in the world. They will protect us.” I called my wife to let her know everyone was safe.
– – I was working for a foreign consulate office in Houston and heard the news during my morning commute. We worked in the tallest skyscraper downtown that was evacuated for fear that it was a target due to oil interests in the area. Our office was responsible for communicating with and ensuring that all the Japanese expats in Texas and Oklahoma were safe. We were an international team, mourning and in shock, all working to help one another through our grief.
– – After watching U.S. news non-stop, I wanted to know how the world was reacting. That night, I turned on my shortwave radio. The first voice I heard was that of British Prime Minister Tony Blair saying, “We, therefore, here in Britain, stand shoulder to shoulder with our American friends in this hour of tragedy.” I’ll never forget that moment. It demonstrated the fraternal solidarity that underpins our special relationship.
Twenty-five years later, we remember and honor those whose lives were taken on September 11, as well as the countless individuals who answered the call to protect our nation in the years that followed. We remember the members of our Armed Forces, intelligence community, law enforcement, diplomatic corps, and others across government who served in the War on Terror, including those who made the ultimate sacrifice and the veterans who continue to bear the physical and emotional wounds of their service.
We also remember that the response to September 11 was a shared effort among the United States and its allies. In the aftermath of the attacks, NATO invoked Article 5 of the North Atlantic Treaty for the first and only time in its history, affirming that an attack against one ally was an attack against all. Over the years that followed, service members and citizens of allied nations also sacrificed their lives in the common effort to confront terrorism and defend our shared security.
As we mark this 25th anniversary, we hope that you will take time to remember all those we lost, honor all those who served and sacrificed, and reflect on the spirit of unity and common purpose that brought Americans and our allies together in the aftermath of September 11.
Registration Now Open! 2026 Fall Training Conference
Join the Coalition on November 18–19 for the 2026 Fall Training Conference at the Fairview Park Marriott in Falls Church, Virginia! This year’s conference will bring together government and industry leaders for two days of timely discussions on the issues shaping the federal procurement landscape.
Attendees will hear perspectives on the 2026 election results and their implications for the federal market, the latest legislative and budget developments, and key acquisition priorities and initiatives across agencies, including the General Services Administration and the Department of Veterans Affairs. The conference will also provide opportunities to hear directly from government decision makers and connect with colleagues from across the procurement community.
Preview two of this year’s featured speakers below and stay tuned for the release of the full conference agenda!
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
Invest in Success: Coalition Compliance Training Conference
As artificial intelligence becomes increasingly integrated into federal procurement, it is creating new opportunities for government contractors, along with new questions surrounding ethics, compliance, and risk.
At the Coalition’s Invest in Success: Compliance Training Conference on October 7, Jessica Tillipman, Associate Dean for Government Procurement Law Studies at The George Washington University Law School, will deliver the keynote session, “Procurement in the Age of AI: Ethics & Compliance in a Changing Federal Marketplace.”
The session 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.
Jessica will also discuss practical compliance considerations for contractors as AI becomes increasingly integrated into their organizations, subcontractors, and federal procurement activities.
Join us on October 7 at CGI Federal in Arlington, Virginia, or virtually to hear Jessica’s insights and learn more about the compliance issues shaping today’s federal marketplace.
View the full agenda here.
To register, Click here. For any assistance with registration, please contact Mady Whiting at mady.whiting@thecgp.org
GSA Directed to Remove Canadian-origin Products from MAS
The White House released a fact sheet this week on the actions the Administration is taking in response to additional tariffs that Canada imposed on American products on September 8. The actions include additional import bans and tariffs on certain Canadian products, as well as a statement that the General Services Administration (GSA) is directed to remove Canadian-origin products from the Multiple Award Schedule (MAS). The Coalition will be monitoring this development and will share any additional information when it is available.
OIG Report on VA FSS Pricing
The Department of Veterans Affairs (VA) Office of Inspector General (OIG) published a Management Advisory Memorandum on the VA Federal Supply Schedules (FSS) program’s pricing policies and procedures. The memo identifies two opportunities to strengthen contractual price protections for the government. The VA FSS program has not yet transitioned to Transactional Data Reporting (TDR), and thus still uses a “tracking customer” to ensure the government is provided a fair price. The price reductions clause ensures the government always gets an equal or better price than the tracking customer. The VA OIG argues that relying on a single tracking custThe Department of Veterans Affairs (VA) Office of Inspector General (OIG) published a Management Advisory Memorandum on the VA Federal Supply Schedules (FSS) program’s pricing policies and procedures. The memo identifies two opportunities to strengthen contractual price protections for the government. The VA FSS program has not yet transitioned to Transactional Data Reporting (TDR), and thus still uses a “tracking customer” to ensure the government is provided a fair price. The price reductions clause ensures the government always gets an equal or better price than the tracking customer. The VA OIG argues that relying on a single tracking customer can leave the government unprotected, particularly when a tracking customer does not routinely buy all the items covered by a VA FSS contract. The OIG suggests VA consider broadening the entities it uses as the tracking customer, for example considering all group purchasing organizations rather than one specific organization. The second opportunity identified focuses on resellers without significant commercial sales. The OIG suggests VA begin requiring manufacturer commercial sales practices and data to support contract proposals and use this information to establish a tracking mechanism for the price reductions clause.
In response to the OIG’s recommendations, leadership of the VA FSS program stated in a written response that, “VA FSS could partner with OIG more to expand routine post award contract audit coverage and remind the FSS contractors more frequently on how to voluntarily offer self-disclosures to assure the protection of the program…” VA FSS leadership also suggested the following to encourage contractors to voluntarily disclose non-compliance:
- Identify as an Annual Contract Review by ensuring the mutually beneficial one-to-one partnership checkup, continue to hold quarterly managerial OIG and FSS syncs to keep both parties informed and proactively plan next quarter and annual partnership.
- Implement Structured Voluntary Disclosure Programs: Establish clear leniency incentives similar to the DOJ Voluntary Self-Disclosure Policy to proactively reward partners that identify and report issues before they are independently uncovered by the VA Office of Inspector General (OIG) or auditors.
- For VA FSS to implement use of ‘Corrective Action Reports’ and/or ‘Letter of concerns’ when FSS industry partner does not comply or supply needed audit artifacts within stated timeframes, for FSS to consider this absence of good-faith and consider the elimination of the product(s) from the FSS schedule and allow the contract to lapse. (*For brand name drugs to be available via Interim Agreements per Public Law 102-585).
For the full report, click here.
GAO Examines DHS Contract Terminations and Cost Savings
The Government Accountability Office (GAO) found that the Department of Homeland Security (DHS) is unlikely to fully realize the $10.5 billion in potential cost avoidance it reported from contract terminations in 2025.
Following Administration directives to review federal contracts and reduce spending, DHS reviewed more than 17,000 contracts and terminated 438 contracts in full or in part between January and September 2025. GAO found that DHS deobligated a net total of more than $92 million from these contracts.
According to GAO, DHS’s $10.5 billion estimate represents the maximum amount that could have been obligated under the terminated contracts, rather than what the agency would have actually spent. GAO also found that 95 percent of the projected cost avoidance was tied to 30 terminated IT contracts. DHS subsequently obligated more than $1.7 billion through existing governmentwide contracts to meet those requirements, reducing the amount of costs actually avoided.
DoW to Offer Mobile SCIFs for Contractors
MeriTalk reports that the Department of War (DoW) has begun establishing the Secure Space Network, which will consist of approximately 50 Sensitive Compartmented Information Facilities (SCIFs) available to contractors. The effort is led by the Office of Industrial Base Growth. Access to secure working environments is consistently identified as a barrier by companies looking to join the defense industrial base. By addressing this barrier, DoW aims to encourage broader industry participation and increased competition on future procurements. DoW plans to establish both fixed-location and mobile facilities. The fixed-location facilities will provide an enduring space for secure collaboration while the mobile facilities will provide rapidly deployable capacity. The Secure Space Network will become a permanent, surge-capable pathway for expanding our nation’s access to secure facilities. A timeline for the effort was not provided.
Federal CIO Plans for AI to Supplement Federal Workforce
Nextgov/FCW reports that the Trump administration is looking to “do more with less” by using AI to help offset significant staffing losses across federal agencies as it works to manage the recent reduction in the federal workforce. Gregory Barbaccia, the federal chief information officer and chief AI officer within the Office of Management and Budget, said AI is a key part of that effort, with the goal of increasing efficiency and automating manual, repetitive tasks.
.USAi and data tools are both major priorities. USAi is a platform designed to help agencies evaluate and adopt AI models from major technology companies. Enterprise data platforms that connect information across organizations can help power AI and advanced analytics, allowing agencies to quickly organize large amounts of information, support employees, and improve government services.
As the administration pushes agencies to share data more easily and expand its use of AI, questions remain about the collection and consolidation of government data, the technology’s reliability and potential for bias, and agencies’ ability to implement and oversee new AI systems given the reduction in experienced federal staff.
Off The Shelf: A look at SBA’s Proposed Size Standards Rule
Ken Dodds, executive vice president and general counsel at the Coalition for Common Sense in Government Procurement, joins Off the Shelf to discuss the implications of the Small Business Administration’s proposed size standards rule and its potential impact on businesses across the federal market.
The proposed rule would make significant changes to federal small-business size standards, including increasing the threshold for IT services from $34 million to $531 million and for consulting services from $24.5 million to $295 million. Dodds discusses how these changes could reshape competition across the federal market and affect businesses classified as small, medium, or large. He also explains the basics of the non-manufacturer rule, including how a waiver can affect a procurement, and shares his perspective on GSA’s proposed AI clause and how it compares with commercial practices.
Listen to the full episode here
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.
GSA Announces New OneGov Agreement with OpenAI
The General Services Administration (GSA) announced a new OneGov agreement with OpenAI that will provide government agencies with discounted, consumption-based access to ChatGPT models. The 27-month agreement is expected to take effect October 1. It is the first agreement under the next phase of GSA’s OneGov AI strategy.
Under the agreement, participating agencies will receive a 50 percent discount on token-based usage across ChatGPT models, including those available in FedRAMP-authorized environments. The agreement does not include platform access fees, minimum orders, or spending commitments, allowing agencies to pay based on their actual usage.
The agreement will be available to federal, state, local, and tribal governments through multiple ordering paths, including direct purchases, resellers, and supported cloud marketplaces. It also includes training and enablement resources and incorporates GSA’s AI terms and conditions to help protect government data.
GSA said that its OneGov agreements have generated approximately $1.68 billion in federal cost savings to date, including approximately $1.4 billion associated with AI agreements that expanded access to AI tools for roughly 3.5 million federal employees. Agencies will be able to procure under the new OpenAI agreement through the GSA Multiple Award Schedule once the offer takes effect.
VA FSS Releases Monthly Update
The Department of Veterans Affairs (VA) has published the VA Federal Supply Schedule (FSS) Medical and Healthcare Field Contracting Notification for August 2026. These monthly notifications provide the latest updates on VA FSS contracting activity.
Highlights from the August edition Include:
- New Contracts: In July 2026, VA-FSS added 7 new contracts available to all VA Contracting Officers (COs) and all Federal COs. State and local governments, including Tribes and Reservations, may also request FSS support for disasters and emergencies.
- FY26 Year-to-Date Highlights: VA-FSS has awarded 179 new contracts, exercised 68 options, and processed 8,338 contract modifications.
VA also provided a table listing the contracts awarded last month.
GSA Moves USAi to Cost-Recovery Pricing Model
FedScoop reports that federal agencies will now pay to use USAi, the government’s artificial intelligence platform. Previously offered at no cost, USAi now operates under a cost-recovery model that includes a platform fee and usage-based charges.
According to GSA’s website, the platform fee is based on an agency’s expected workload, while usage costs are tied to actual consumption. The agency said the change will support growing demand without relying on appropriations.
The update comes as several OneGov AI agreements, including offerings from OpenAI, Google, and Anthropic, are set to expire this month. GSA said the agency is working with vendors on extensions and potential new offers.
Technology Modernization Fund to Announce New Investments Soon
FedScoop reports that the Technology Modernization Fund (TMF) plans to publish “savings and value return numbers” for fiscal 2025 shortly. It will also announce new investments by the end of September.
Established in 2017, the TMF provides funding to agencies for specific technology modernization projects. Savings accrued from these projects are directed back to the fund for new investments.
The TMF Board selects which projects to fund and monitors their progress. According to FedScoop, the TMF Board recently added four new individuals. Carter Farmer, the Environmental Protection Agency’s chief information officer, was appointed as a full voting member. Nikki Collier, the Department of Justice’s CIO, Thomas Flagg, the Office of Management and Budget’s deputy federal CIO, and Jeffrey Post, a senior advisor at GSA, were all appointed as alternate members. They only vote if needed to reach a quorum.
DOJ Launches the National Fraud Detection Center
By J. Ryan Frazee, John Prairie, Arun G. Rao, Findley 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.
EO Directs VA and DoW Data Sharing
Nextgov/FCW reports on an executive order directing the Department of War and Department of Veterans Affairs to conduct a review of information technology-related contracts. A White House fact sheet outlines the directives under the EO aimed at improving data sharing between IT systems to help veterans access benefits and services more quickly.
Under the order, DoW has 30 days to ensure military personnel files, health records and service treatment records are shared with the VA when service members leave the military. In addition, DoW and VA have 120 days to review existing IT systems and software contracts and 180 days to establish systems for ongoing record sharing and to deploy AI and other digital tools to streamline benefits applications. DoW and the VA must also create a centralized source for employment and job-training opportunities. VA estimates that improved data sharing could reduce benefits processing times for recently separated service members by 20 to 30 days.