FAR & Beyond Blog
Looking Ahead to a Week of Federal Procurement Events
After a successful Invest in Success Compliance Training Conference this week, we are looking forward to a busy November filled with opportunities for members to engage on key issues across the federal marketplace. Before turning to what’s ahead, we would like to thank everyone who joined us this week and helped make our inaugural Compliance Training Conference a success.
More than 200 members of the government contracting community participated in person and virtually for a morning of timely discussions focused on the compliance issues impacting today’s federal marketplace.
A special thank you goes to our outstanding speakers and panelists for sharing their expertise and perspectives.
Jessica Tillipman of The George Washington University Law School discussed Procurement in the Age of AI: Ethics & Compliance in a Changing Federal Marketplace, exploring the evolving ethical and compliance considerations surrounding the use of artificial intelligence (AI) in federal procurement.
Jonathan Aronie of Sheppard Mullin led a discussion on Active Bystandership: The Missing Link in Corporate Risk Reduction, examining the role employees can play in identifying and addressing potential risks before they escalate.
Chris Terranova of the U.S. Department of Justice; Alexander Canizares of Vinson & Elkins; Terra Fulham of Covington & Burling; and Tirzah Lollar of Arnold & Porter spoke on the Compliance and the Civil False Claims Act (FCA) panel that brought together government and industry perspectives on FCA obligations and risks for federal contractors.
The Coalition thanks CGI Federal for generously hosting the conference and helping make our inaugural program possible.
Looking Ahead to a Week of Federal Procurement
The Coalition is now looking ahead to a busy November and what is quickly becoming a “Federal Procurement Week” at the Fairview Park Marriott in Falls Church, Virginia.
From November 17 through November 20, members will have four consecutive days of training and opportunities for open dialogue on key Federal contract programs and customer agencies.
November 17: AInAcquisition Exchange Forum – The Future is Now
The week will begin on Tuesday, November 17 with the Coalition’s inaugural AInAcquisition Exchange Forum: The Future is Now.
AI is already transforming how federal agencies conduct procurements and manage technology, while also raising new considerations for the acquisition community. The half-day forum will bring together government and industry leaders to discuss the evolving role of AI across the federal marketplace.
The program will feature discussions focused on the federal government’s AI strategy and the road ahead, the role of AI in federal IT management, and the evolving AI acquisition policy landscape. Speakers will offer perspectives on how agencies are approaching AI adoption and the policies that will help guide how the government acquires and uses the technology.
The Coalition extends its sincere appreciation to SAIC for sponsoring the AInAcquisition Exchange Forum.
Registration for the November 17 forum is complimentary for all Fall Training Conference registrants. Those already registered for the Fall Training Conference can update their registration to indicate that they plan to attend the forum.
To register for the AInAcquisition Forum, click here. For assistance, please contact Mady Whiting at mady.whiting@thecgp.org.
November 18–19: Fall Training Conference – The Acquisition Exchange
The conversation will continue November 18–19 with the Coalition’s 2026 Fall Training Conference: The Acquisition Exchange. The conference will bring together government and industry leaders for two days focused on the priorities and developments impacting the federal marketplace.
Day One, What’s Next for Interagency Contracting? will focus on the future of the government-wide acquisition marketplace. Former Congressman Tom Davis will kick off the conference with a post-election breakdown of what happened and what to expect in the new Congress. The main stage agenda will also feature discussions on the connection between acquisition policy and operations, budget and legislative developments, General Services Administration (GSA) acquisition priorities, and other procurement hot topics.
Attendees will have the opportunity to participate in Nuts & Bolts sessions featuring key organizations within GSA’s recently reorganized Federal Acquisition Service (FAS) and other agency programs. Sessions will cover GSA’s ASSIST, CENTRALIZE, CREATE, DELIVER offices, the Multiple Award Schedule, OneGov, NASA SEWP, Federal Acquisition Service Systems, and the GSA Acquisition Regulation (GSAR) Rewrite.
View the full Day One agenda here.
Day Two, What’s Next for Healthcare Procurement? will turn the focus to the federal healthcare marketplace. Coalition Defense Fellow and Etherton & Associates President Moshe Schwartz will provide a Keynote Address on budget and legislative developments impacting federal healthcare contractors. On the main stage, acquisition officials and experts will discuss Department of Veterans Affairs (VA) acquisition priorities and operations, Made in America, and developments on Capitol Hill.
Healthcare-focused Nuts & Bolts sessions will provide opportunities to explore VA and Indian Health Service pharmacy programs, healthcare cybersecurity, the Defense Health Agency Pharmaceutical Program, the VA Federal Supply Schedules Program, and the VA medical/surgical prime vendor (MSPV) program.
View the full Day Two agenda here.
To register for the Fall Training Conference, click here. For assistance, please contact Mady Whiting at mady.whiting@thecgp.org.
Just Announced: VA Pharmaceutical Industry Day on November 20
The week will now extend one more day with a newly announced opportunity for the pharmaceutical community.
On November 20, the Department of Veterans Affairs (VA) Enterprise Procurement Office, Office of Acquisition, Logistics, and Construction, in collaboration with the Coalition, will host an in-person Pharmaceutical Industry Day at the Fairview Park Marriott in Falls Church, Virginia, the same location as the AInAcquisition Exchange Forum and Fall Training Conference.
The event will bring together government and industry leaders to discuss the latest developments and challenges affecting federal pharmaceutical procurement. Discussions will focus on policy changes, emerging procurement priorities, and opportunities to strengthen collaboration between VA and its pharmaceutical industry partners. The Industry Day will also support ongoing efforts to improve transparency and efficiency in the acquisition of pharmaceutical products for our nation’s Veterans.
Registration is now open! Due to limited capacity, attendance is restricted to two representatives per company, with registrations approved on a first-come, first-served basis. Interested attendees are encouraged to register here.
Questions regarding the event’s subject matter may be submitted in advance to Regina McGregor, Director of Business Development & Small Business Technical Advisor, EPO, at Regina.McGregor@va.gov..
Join Us for a Week of Federal Procurement
From November 17 through November 20, Coalition members will have four consecutive days of opportunities to hear from government leaders, connect with colleagues, and learn about developments affecting the federal marketplace.
We look forward to welcoming members to Fairview Park for an exciting week of federal procurement!
Sponsorship Opportunities Available for the 2026 Fall Training Conference!
Make Your Brand Stand Out at the 2026 Fall Training Conference! Sponsorship opportunities are still available!
Showcase your company at the Coalition’s 2026 Fall Training Conference: The Acquisition Exchange, taking place November 18–19 at the Fairview Park Marriott in Falls Church, Virginia.
The Fall Training Conference brings together leaders and professionals from across the government contracting community for two days of timely discussions, direct engagement, and valuable networking.
Put your company in front of industry peers, decision-makers, and high-level acquisition officials at our upcoming conference. Sponsorship provides a valuable opportunity to increase brand visibility, strengthen relationships, showcase your organization, and connect directly with potential customers and partners.
With a variety of sponsorship opportunities still available, your company can build its presence throughout one of the Coalition’s signature annual events.
Don’t miss the opportunity to put your brand front and center at the 2026 Fall Training Conference! 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
New “Super Intelligence Force” to Coordinate Federal AI Policy
MeriTalk reports that a new “Super Intelligence Force” has been established by the President to coordinate the federal government’s approach to artificial intelligence (AI), which the administration now refers to as “super intelligence” or “SI.” The group will engage with AI companies, critical infrastructure providers, consumers, and other stakeholders as the administration develops its approach to the technology.
Director of National Intelligence Jay Clayton will lead the group alongside FCP Chairman Andrew Ferguson, War Department CTO Emil Michael, and OPM Director Scott Kupor. The announcement follows other administration actions emphasizing AI development while generally opposing broader federal regulation of the technology.
Scam Alert: Fraudulent Emails Impersonating GSA
The Office of Inspector General (OIG) at the General Services Administration (GSA) issued a scam alert warning contractors about fraudulent emails impersonating GSA contracting officials. The emails use real officials’ names and signatures but come from look-alike domains rather than legitimate @gsa.gov addresses. Reported scams have included fake vendor credentialing fees and false contract compliance notices, often requesting payment or sensitive information.
Contractors should verify the sender’s full email domain, independently confirm unexpected requests, avoid opening unsolicited attachments or providing financial information, and report suspected scams to their GSA contracting officer and the GSA OIG hotline.
GSA Advance Notice of MAS Refresh #34 and Mass Modification
A GSA Multiple Award Schedule (MAS) Interact community post announced that the Federal Acquisition Service (FAS) plans to issue MAS Solicitation Refresh #34 on Nov. 6, 2026. Contractors will have 90 days to accept the associated mass modification, which will apply to new task and delivery orders issued after its effective date, including calls under existing Blanket Purchase Agreements (BPAs).
Key changes include:
- GSAR Overhaul Wave 4: Removes the 20-year contract duration limit, consolidates several GSAR and FSS clauses, and adds a new AI-related clause addressing risks associated with large language model systems.
- FSS Domestic End Product Certification: Introduces a voluntary certification for contractors to identify listed products as FSS domestic end products.
- Covered Nitrile Gloves: GSA plans to remove certain domestically manufactured nitrile gloves from MAS contracts as it consolidates federal demand through a DHS contract.
- SIN 561210FAC Facilities Support Services: Removes HVAC maintenance as a standalone offering.
- SIN 54151HACS Highly Adaptive Cybersecurity Services: Phases out the voluntary Incident Response subgroup by the end of FY 2027.
GSA FAS will host a public webinar on MAS Refresh #34 and the upcoming mass modification on Oct. 26, 2026, from 1:00 – 2:00 PM (ET). For additional information on the webinar, click here.
GSA is also accepting comments on the proposed changes in MAS Refresh #34 through the MAS Community page on GSA Interact.
Just Announced: VA Pharma Industry Day on November 20
On November 20, the Department of Veterans Affairs (VA) Enterprise Procurement Office, Office of Acquisition, Logistics, and Construction, in collaboration with the Coalition, will host an in-person Pharmaceutical Industry Day at the Fairview Park Marriott in Falls Church, Virginia, the same location as the AInAcquisition Exchange Forum and Fall Training Conference.
The event will bring together government and industry leaders to discuss the latest developments and challenges affecting federal pharmaceutical procurement. Discussions will focus on policy changes, emerging procurement priorities, and opportunities to strengthen collaboration between VA and its pharmaceutical industry partners. The Industry Day will also support ongoing efforts to improve transparency and efficiency in the acquisition of pharmaceutical products for our nation’s Veterans.
Registration is now open! Due to limited capacity, attendance is restricted to two representatives per company, with registrations approved on a first-come, first-served basis. Interested attendees are encouraged to register here.
Questions regarding the event’s subject matter may be submitted in advance to Regina McGregor, Director of Business Development & Small Business Technical Advisor, EPO, at Regina.McGregor@va.gov.
Welcome Kayden to the Coalition!
Join us in welcoming Kayden Austin-Vaias to the Coalition team! As Policy Analyst, Kayden will be assisting the Pharmaceutical and IT/Services Committees and working on acquisition policy related projects like the Management of the Multiple Awards Policy and Procedures (MMAPPs) Working Group.
Kayden joins us following her graduation in May 2026 with a Master of Public Administration (MPA) degree from the University of Delaware, with a specialization in Public Policy Analysis. She also has a BA in Public Policy & Criminal Justice from the University of Delaware. Please join us in welcoming Kayden Austin-Vaias (KAustin-Vaias@thecgp.org) to the Procurement Community!
GSA’s Revised AI Clause
Fedscoop reports that GSA’s revised AI clause has received praise from some industry stakeholders though concerns remain. The requirement for purchased AI to only follow “unbiased AI principals” has been mostly removed. However, contractors are still required to use testing methods that follow “unbiased AI principles.” Additionally, the government continues to reserve the right to evaluate large language models for “unsolicited ideological content.”
The approach taken in the revised AI clause is based on three questions that can be used to determine whether information should be considered protected government data: The three questions are: Is it tied to government use? Does it reveal how the government operates? And can that conclusion be drawn even if no single record reveals it?
Experts state that the government usage context definition better clarifies the government’s position on protected data, but additional work may be necessary.
Coalition Collecting Comments on GSAR AI Clause
The Coalition for Common Sense in Government Procurement is collecting comments from industry on the new General Services Acquisition Regulation (GSAR) artificial-intelligence clause. The clause is located at GSAR 552.239-7001 (See pg. 129) and is entitled “Safeguarding of Data within Large Language Model Artificial Intelligence Systems.” GSA collected comments on a previous draft AI clause. The Coalition’s comments may be found here. Please provide any comments you have regarding the new AI clause to Greg Waldron at gwaldron@thecgp.org by the end of the day on October 15.
DHS Plans $626 Million Cyber, Cloud Contract
Federal News Network reports that the Department of Homeland Security (DHS) expects to award its Network, Cloud and Cybersecurity Services 2.0 (NCCS 2.0) contract by late November. With a potential $626 million ceiling, the vehicle will provide cybersecurity, network operations, cloud, and related professional support services for the DHS Office of the Chief Information Officer (OCIO) and select components.
DHS plans to issue the final solicitation in early October. The contract is intended to further consolidate the management of DHS network and cybersecurity services, including evolving the headquarters Network Operations and Service Center into a central hub for managing network infrastructure, platforms, and cybersecurity across DHS OneNet.
Bill to Reduce Minimum Education Standards Passes Senate
Fedscoop reports that the Skills-Based Federal Contracting Act has passed both the House and Senate. The bill will ban federal agencies from including minimum education standards into contract solicitations, unless the agency includes a written explanation justifying those requirements as mission critical. The bill’s sponsor, Nancy Mace (R-NC), stated at a press briefing that “This opens up thousands of jobs to people who deserve them, and so it is a jobs bill. It is a middle-class American workers bill. If you have the skills, you should get the job.”
Google Extends OneGov Gemini Deal Through November 15
FedScoop reports that Google has extended its OneGov agreement with GSA on Gemini for Government through November 15. The deal, originally set to expire September 30, offers agencies Gemini and other Google AI tools for $0.47 per agency for one year, along with a 20% discount on first-party Google Cloud services.
The agreement also includes FedRAMP High-authorized Google Cloud Platform products and builds a previous 71% discount for Google Workspace. The extension follows recent OneGov agreements and extensions involving Anthropic’s Claude and OpenAI’s ChatGPT.
SBA Publishes New Size Standard Impact Assessment
The Small Business Administration (SBA) published a new assessment clarifying how the agency sees the Revised Size Standards Methodology and Small Business Size Standards proposed rules impacting the federal market. The assessment states that 114,000 existing firms across the U.S. economy (not just federal contracting) could newly qualify as small, a 0.315% increase in US small businesses. The assessment finds that 1,523 active federal contractors could gain small business status. An additional 1,401 active federal contractors who are considered small in one industry could qualify for small business status in one or more additional industries. Previous SBA analysis indicated that 4,000-6,000 small entities could gain small status. “Small entities” included nonprofit organizations, local government, and other groups along with for-profit businesses.
The comment period for the two proposed rules has been extended to November 20. The Coalition submitted comments before the initial deadline of September 21. They are posted on our website here for members to review. If members have additional comments that you would like the Coalition to submit by the extended deadline, please email them to Greg Waldron at gwaldron@thecgp.org by the end of the day on November 6.
Legal Corner
The Protest Clock May Start Sooner Than You Think in a FAR 8.4 Procurement: GAO Dismisses Untimely FSS Protest in Hendall Inc.
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.
By Evan Williams & David O’Neill on October 8, 2026
GAO’s bid protest timeliness rules are strict. Even a strong protest can be dismissed if it is not filed within the deadline established by GAO regulations. In certain procurements, required debriefings can affect protest deadlines while voluntary debriefings or brief explanations in other types of procurements do not toll deadlines.
In Hendall Inc., B-423714.5 (Oct. 1, 2026), the Government Accountability Office (GAO) dismissed a bid protest as untimely because it was filed more than 10 days after the protester knew, or should have known, its grounds for protest. The protester argued that its protest was timely because it was filed within 10 days of the agency’s “brief explanation” of the award decision. GAO rejected that argument and ruled that the protest clock started earlier, when Hendall received notice of the award.
The decision is a reminder that a contractor cannot assume that a post-award explanation tolls the GAO deadline. The debriefing exception applies only when the procurement is conducted on the basis of competitive proposals and the debriefing is required. For a Federal Supply Schedule (FSS) procurement, a requested brief explanation does not itself reset the clock. Below, we discuss the case and offer practical guidance for contractors who receive a notice of non-award.
Hendall Inc., B-423714.5 (Oct. 1, 2026)
The Centers for Medicare and Medicaid Services (CMS) issued a request for quotations (RFQ) under the General Services Administration’s (GSA) FSS program, using the streamlined ordering procedures of Federal Acquisition Regulation (FAR) subpart 8.4, for management of its Comprehensive Error Rate Testing program. The procurement had a long history of protests and corrective action.
After Hendall was excluded from the competitive range, it protested to GAO in August 2025. In that protest, Hendall argued the agency conducted an impermissible price realism analysis. CMS took corrective action and reopened discussions with Hendall. In November 2025, CMS selected Serco, Inc. for award. Hendall protested again on December 1, 2025, and GAO dismissed that protest after another vendor filed a related protest at the U.S. Court of Federal Claims (COFC). CMS then took corrective action in the COFC protest and reevaluated the quotations. On May 28, 2026, CMS notified Hendall that it had not been selected for award. Hendall requested a brief explanation, which CMS provided on June 16. Hendall filed its protest with GAO on June 26, 2026.
GAO found Hendall’s protest untimely, applying the strict timeliness rules in its bid protest regulations. Under GAO’s bid protest regulations, protests not based on alleged improprieties in the solicitation itself must be filed within 10 days after the protester knew or should have known the basis for protest, whichever is earlier.[1] There is one important exception. For procurements conducted on the basis of competitive proposals where a debriefing is requested and required, such as FAR part 15 negotiated procurements and, in some cases, FAR subpart 16.5 task order competitions, a protest must be filed within 10 days after the debriefing is held.
Because CMS conducted the procurement under FAR subpart 8.4, the FAR part 15 debriefing requirements did not apply. In FSS procurements, the FAR requires agencies to provide only a “brief explanation of the basis” for the award decision, and only upon request. GAO explained that a brief explanation is not a required debriefing and is no different from any other source of information about the award for timeliness purposes. As a result, GAO held that Hendall’s protest clock began on May 28, 2026, when Hendall received notice that it had not been selected for award.
Hendall argued that it had no basis for a “knowledgeable or supportable” protest until it received the June 16 brief explanation. GAO disagreed, noting that a protester “need not await perfect knowledge” and may not delay filing until it can detail every possible protest ground. GAO further observed that Hendall already knew of both of its protest grounds—challenges to the agency’s price realism and tradeoff analyses—because it had raised them in its prior protests.
Key Takeaways for Contractors
GAO’s decision in Hendall underscores the importance of understanding the deadline for protest and whether a required debriefing can extend it. Contractors should keep the following points in mind:
- Consult counsel immediately after receiving a notice of non-award to assess timeliness, debriefing options, and potential protest grounds. Experienced counsel can review the timeline, including the award notice, which may have already started the protest clock. Counsel can then advise on whether to request a debriefing, key questions, protest options and forums, and help evaluate the strength of potential protest grounds early.
- Understand whether a debriefing is required. This distinction can determine whether a protest survives. In FAR part 15 procurements, and in some FAR subpart 16.5 task order competitions, a required debriefing that is timely requested can extend the GAO filing deadline to 10 days after the debriefing is held.[2] By contrast, voluntary debriefings, brief explanations, and other information provided by agencies do not extend protest deadlines.
- Do not wait for additional information if you already know your protest grounds. GAO does not require perfect knowledge before a protest is filed. If the award notice, or prior protests and corrective action, already reveal the basis for a challenge, the 10-day clock is likely already running
The bottom line is that contractors considering a protest should contact counsel immediately when an unfavorable award notice arrives. This is especially important in an FSS or other non-FAR part 15 procurement, where the protest clock has likely started and time is limited.
[1] 4 C.F.R. § 21.2(a)(2)
[2] The automatic Competition in Contracting Act (CICA) stay deadline is separate from GAO’s 10-day timeliness rule. In a post-award context, a GAO protest must generally be filed within 5 days after a required debriefing in order to trigger a CICA stay. 31 USC § 3553(d)(4).
Healthcare Spotlight
VA FSS Announces Public Law Season Webinar
The Department of Veterans Affairs (VA) Federal Supply Schedule (FSS) Service is hosting webinars covering 2027 Public Law (PL) annual pricing updates, including key timelines and guidance for contractors on completing required PL forms. The first session was held on October 8, and a second session covering the same material will be held October 22 from 10:00 AM to 12:00 PM Central Time. The login information is provided in the webinar announcement here.
GSA Briefing on Highly Configurable Items and FCP, October 14
GSA will brief members on October 14, 2026, from 12:00–1:00 PM (ET) on the reporting and uploading of Highly Configurable Products (HCPs) in the FAS Catalog Platform (FCP).
Designed for members of the Imaging Equipment, Furniture, and IT/Services Committees, the meeting will feature Holly Caputo, Supervisory Contract Specialist, and Peter Han, Director of the Office of Acquisition Solutions Development. GSA will provide an overview of the preferred process for reporting and uploading HCPs, including guidance on HCP pricing structures.
To facilitate discussion, members are encouraged to submit their questions ahead of time to Joseph Snyderwine at JSnyderwine@thecgp.org.
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.
Coalition Holiday Reception, December 15
The holiday season will be here before we know it! Join us on December 15 at the Tower Club in Tysons Corner for our annual holiday reception from 5:00–8:00 PM ET.
As we wrap up another event-filled year, we invite you to take a break to celebrate all that we’ve accomplished together with your Coalition friends and colleagues. Enjoy an evening of food, beverages, and good company as we toast to the year ahead.
To register, click here. For any assistance with registration, please contact Mady Whiting at mady.whiting@thecgp.org.
Note: This is a member-only event. Registration is complimentary but required for food and beverage purposes.