HKA Government Contracting Quarterly Regulatory Update
11th February 2025
Winter 2025
National Defense Authorization Act for Fiscal Year 2025
The National Defense Authorization Act for Fiscal Year 2025 contains numerous provisions that are impactful to government contractors.
CAS Board – Advanced Notice of Proposed Rulemaking
The CAS Board released an advance notice of proposed rulemaking to elicit comments on its efforts to conform CAS 404 and CAS 411 to GAAP.
DoD Final Rule – Material Weakness for DFARS Business System Evaluations
DoD issued a final rule to define the term “material weakness” within the context of DFARS business systems evaluations and replace the term “significant deficiency.”
Department of Justice Report on False Claims Act Settlements and Judgments
The Department of Justice announced that FCA settlements for the government’s fiscal year 2024 exceeded $2.9 billion.
President Trump’s Executive Orders
During his first few weeks in office, President Trump has signed numerous executive orders likely to impact the government contracting community.
DCAA Memorandum for Regional Directors
The Defense Contract Audit Agency (DCAA) released a Memorandum for Regional Directors (MRD) providing the Office of Federal Procurement Policy contract compensation cap of $671,000.
FAR Proposed Rule to Adjust Certain Thresholds to Account for Inflation
The DoD, GSA, and National Aeronautics and Space Administration (NASA) issued a proposed rule to amend the Federal Acquisition Regulation (FAR) to adjust certain statutory acquisition-related thresholds to account for inflation.
FAR Council Announced It Was Withdrawing Certain Proposed Rules
FAR Council announced it was withdrawing the Pay Equity and Transparency in Federal Contracting proposed rule to amend the FAR and withdrew a proposed rule related to the Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk.
DoD Final Rule – Applicability of Certain Contract Clauses to Commercial Products and Services
DoD issued a final rule to address the applicability of certain contract clauses and solicitation provisions to commercial products and services and commercially available off-the-shelf (COTS) items.
Small Business Updates
Among other updates, the Small Business Administration (SBA) issued a proposed rule designed to “encourage faster payments to small business subcontractors and streamline the reporting process for prime contracts.”
Pilot Program to Increase Progress Payment Rate
DoD issued a notice seeking public input for the purpose of implementing Section 874 of the NDAA for FY 2024.
Proposed Rule – Organizational Conflicts of Interest
DoD, GSA, and NASA issued a proposed rule to amend the FAR to revise guidance, definitions, and examples of organizational conflicts of interest (OCIs).
