TWIG-C™ – April 6, 2026

Apr 6, 2026 | TWIG-C™

GOVCON INSIGHTS AND INFORMATION:

Faster to the Fight: How the Navy is Reengineering SBIR/STTR Innovation – Earlier this month, the U.S. Navy announced a significant overhaul of its Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs, with a renewed emphasis on speed, efficiency, and commercialization. The changes are intended to accelerate how quickly innovative technologies move from concept to deployment, which is unsurprising given the U.S. Department of War’s (DOW) focus on speed and supporting the warfighter. As these reforms begin to take shape, small business contractors should make efforts to assess their commercialization readiness while balancing their compliance requirements.

Artificial Intelligence (AI): OMB Action Needed to Address Privacy-Related Gaps in Federal Guidance – On March 26, GAO released a report detailing its review of the risks and challenges associated with protecting privacy when using AI and the extent to which OMB addressed these risks and challenges in government-wide guidance. GAO assembled a panel of experts and compiled a non-exhaustive list of privacy risks and challenges associated with AI. GAO also reviewed OMB’s AI-related guidance to determine if it highlighted the specific types of privacy risks identified by the experts. Further, GAO compared OMB’s AI-related government-wide guidance to 10 selected challenges to determine if they could be addressed by the contents of the guidance.

Former Member of the Air Force Pleads Guilty to Multi-Year Bid Rigging Schemes and Conspiracy to Defraud U.S. Air Force – A former active-duty Master Sergeant of the U.S. Air Force pleaded guilty yesterday to fraudulently inflating the cost of information technology (IT) contracts for the U.S. Pacific Air Forces (PACAF) by at least $37 million — and using the excess funds to enrich himself, enrich co-conspirators, and channel bribes to a federal public official in PACAF whom the conspirators nicknamed “Godfather.” The defendant, Alan Hayward James, 51, of Texas, pleaded guilty to conspiracy to commit wire fraud, bribery, and conspiracy to rig bids. James also agreed to pay over $1.4 million in restitution to the U.S. Department of War.

GSA’s New Proposed “American AI” Clause for Schedule Contracts: What Contractors Need to Know – On March 6, 2026, GSA dropped a surprising new proposed GSAR clause it plans to roll into GSA Schedule contracts in the next MAS refresh (Refresh 31, expected late March or April). The clause—GSAR 552.239-7001, “Basic Safeguarding of Artificial Intelligence Systems”—is a big deal for any contractor selling through the Schedules program, and potentially for their subcontractors and “service providers,” too. GSA released the proposed clause via the Schedule refresh comment process—not through traditional notice-and-comment rulemaking. Thus, there is a very short window to submit feedback—GSA is accepting comments on the proposed clause only through March 20, 2026 (either in the “comments” section of the webpage or to the MAS Program Management Office email (maspmo@gsa.gov)).

Back to Basics: Requests for Equitable Adjustment – As any contractor knows, there is no amount of preparation that can ensure a project goes exactly as planned. And unfortunately, when the unexpected happens, contractors may face increased costs, schedule delays, and other obstacles outside of their control. A request for equitable adjustment (or REA) affords contractors the opportunity to seek compensation or additional time for unforeseen conditions. This post will explore REAs and when to consider using such an approach.

“In Scope” vs. “Out of Scope” Modifications: How GAO Explains The Difference – One of the perennially popular topics on SmallGovCon has been the question of what constitutes a modification to a contract that renders that modification “Out of Scope.” This post will explore a leading GAO decision that came out back in 2017, along with some recent updates on this same question. An agency may modify a contract without having to deal with restrictions in the Competition in Contracting Act (CICA), so long as the the modification is deemed “in scope.” An “out of scope” modification, on the other hand, is improper–and may be protested at GAO.

GAO Evaluation of CMMC Program and Important Information for Defense Contractors – Back in October and November 2025, with the Department of Defense putting some finishing touches on the Cybersecurity Maturity Model Certification (“CMMC”) Program, we explored the contours of that program and what it means for contractors like you. During this same timeframe, we were not the only ones reviewing the CMMC Program. The GAO also has been in the process of conducting a review of the CMMC Program and recently released its findings. In a report titled, “Defense Contractor Cybersecurity: DOD Should Address External Factors That Could Impede Program Implementation,” GAO’s position on the CMMC Program is pretty clear: Good but needs tweaking. Today, we’ll take a look at those findings and how they might affect the CMMC Program going forward.

Will AI cut the average 18-month acquisition timeline? – For as long as I can remember, federal acquisition leaders and the commercial industry have been asking the same question: why does it take so long to buy what the government already knows it needs? And for years, the answer has been this: The architecture of procurement and a pre-defined calendar that bleeds 18 months before a contract could be close to hitting the street. That timeline is a strategic vulnerability. Every month locked inside a PDF labyrinth is a month an adversary can field the next drone, the next missile, the next exploit. China is pushing autonomous systems from lab bench to field unit in 18-month sprints. Ukraine went from four garage drone builders to 500 registered manufacturers in 24 months. And we are still budgeting 600 days just to move from solicitation to signed contract. The architecture of acquisition work has not fundamentally changed since the Federal Acquisition Regulation (FAR) was compiled in 1984. That is the gap we have to close.

Rewriting FedRAMP: Inside the Push to Modernize Federal Cloud Security – his week on the GovNavigators Show, Adam and Robert sit down with Ryan Hoesing, Chief of Staff for FedRAMP, and Nicole Thompson, Security Director, for a deep dive into one of the most consequential federal IT programs undergoing transformation today. Ryan and Nicole walk through the sweeping changes to the FedRAMP program and explain what the new “FedRAMP 20x” approach means for agencies and industry. They unpack the shift from authorization to certification, the move toward continuous and machine-readable security data, and why redefining FedRAMP’s role is critical to making cloud adoption actually work across government.

Buy American and Made in USA: One slogan, two compliance systems – Business executives and their legal counsel have a common, yet avoidable, problem: Companies treat domestic-content compliance for federal work as permission to brand products as Made in USA, and recycle marketing claims into bid packages as shorthand for procurement eligibility. Those shortcuts are where risk starts, because “Buy American” and “Made in USA” are different legal regimes with different tests, owners and enforcement pathways. In the wake of President Donald Trump’s March 13 executive order, Ensuring Truthful Advertising of Products Claiming to be Made in America, companies must remain vigilant and ensure that their business and legal teams are aligned on American-origin claims, lest a company’s marketing claims land them in the government’s crosshairs.

DHS Cancels Policy Requiring Secretary to Review Contracts Over $100K – U.S. Homeland Security Secretary Markwayne Mullin on Wednesday rescinded a policy requiring the secretary to approve contracts over $100,000, the Department of ‌Homeland Security said. The news followed a re-evaluation of the department’s contract process, DHS said, while adding that Mullin wanted to make sure the department is serving American taxpayers efficiently.

New EO on Addressing DEI Discrimination by Federal Contractors:

From PilieroMazza – Trump Administration’s Latest Executive Order on DEI Requires Immediate Action for Government Contractors – On March 26, 2026, the Trump Administration issued a new Executive Order (EO) targeting diversity, equity, and inclusion (DEI) policies for federal contractors. The EO continues the Trump Administration’s hyper-trained focus on DEI, or what the President believes constitutes “racial discrimination in American society.” It follows a Department of Justice (DOJ) memorandum issued in May 2025 in which DOJ indicated it would utilize the False Claims Act (FCA) to target DEI policies for federal contractors, educational institutions, and companies doing business with the federal government. In the latest EO, the President states that “DEI activities are not only unethical and often illegal, but also cause inefficiencies, waste, and abuse within entities that engage in such practices” and raises concerns that the alleged costs associated with federal contractors’ DEI policies are then passed on to the government. Visit this link to register for our webinar on this important topic for government contractors.

Navigating the Termination Threat of President Trump’s Latest DEI Executive Order for Government Contractors – On March 26, 2026, the Trump Administration issued a new Executive Order (EO) that all-but promises contract termination for federal contractors whose diversity, equity, and inclusion (DEI) policies are deemed non-compliant with the EO. The EO builds on the Administration’s ongoing scrutiny of DEI initiatives, following a May 2025 Department of Justice (DOJ) memorandum signaling the use of the False Claims Act (FCA) to challenge DEI practices within federal contracting, higher education, and other federally funded entities. This blog specifically addresses what contractors need to know when faced with the EO’s immediate and significant threat of contract termination for prime contractors and subcontractors who fail to ensure strict compliance with the EO.

From Morrison Foerster – President Issues New “DEI Discrimination” Executive Order Directed at Federal Contractors and Subcontractors – As part of continued efforts by the administration to combat diversity, equity, and inclusion (“DEI”) activities in government procurement, President Trump issued a new Executive Order, Addressing DEI Discrimination by Federal Contractors, on March 26, 2026 (the “DEI EO”). The DEI EO directs federal agencies to include specific, mandatory DEI-related language in federal contracts and requires that the language also be flowed down to subcontractors. The proposed contract language prohibits “racially discriminatory DEI activities” and invokes potential noncompliance punishments ranging from contract termination to debarment to False Claims Act (“FCA”) liability. The DEI EO thus goes farther than previous administration pronouncements and policy directives, such as Executive Order 14174, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, which raised the specter of FCA enforcement and contract DEI clauses but was short on detail (see prior article). Contractors and subcontractors should take note and prepare for compliance with the forthcoming contract clause.

OPPORTUNITIES:

Army RFI: Commercial Software.
SpOC RFI: CNECTS.
VA RFI: LEO Satellite Equipment and Services.
USAF RFI: HQ AFRC A-E Facilities Support and Environmental Services.
DOD RFI: DARC ICS Contract.
NGA RFI: Police Modernization.
NASA RFI: Mission Integration Prime for GeoXO Series Satellites.
DOE RFI: Advancing Critical, Emerging Microelectronics Tech.
USN RFI: Engineering, Technical, Repair, and Program Management Support.
NATO RFI: ISR Collection Orchestration Service.
HHS RFI: Federal Occupational Health (FOH) Private Provider Network (FOHNet).
NASA RFI: Sustained Lunar Base Support.
Army Issues RFP for $50B MAPS Contract Vehicle for IT, Professional Services