TWIG-C™ – April 13, 2026

Apr 13, 2026 | TWIG-C™

GOVCON INSIGHTS AND INFORMATION:

Comments on proposed AI Clause, GSAR 552.239-7001 – Three industry associations sent more than 40 pages of comments to the General Services Administration regarding their proposed changes to the schedules program around artificial intelligence. And it’s clear, the Coalition for Common Sense in Government Procurement, the Alliance for Digital Innovation and the IT Industry Council have deep concerns about GSA’s initial attempt to increase governance over the AI tools agencies buy through them. CGP told GSA its members say the AI clause as written may have a “chilling effect on contractor use and adoption of AI” as the clause “raises significant concerns about practicality, enforceability and market accessibility.” ADI’s comments build on what the CGP highlighted. The association told GSA that the current rules would “create compliance burdens that are difficult, if not impossible to reconcile with how commercial AI products are built, licensed and delivered.” To that end, ADI says the current clause is “likely to deter nascent and emerging AI providers” from doing work with the government. Finally, ITIC weighed in with equal concerns about how GSA is deviating from commercial best practices. ITIC also says, “GSA’s approach … runs counter to the Trump administration’s stated goals of promoting cost savings and efficiencies in the procurement process through the use of commercial technologies.” Let’s hope these and other comments resonate with GSA as they continue to develop the new AI clause for schedule contracts.

Federal transparency improved on paper; key gaps still undermine integrity: GAO – Congress and federal agencies have taken steps to improve transparency around spending and programs, but GAO says persistent gaps continue to limit oversight, efficiency and program integrity. From incomplete spending data to FOIA backlogs and missing program inventories, these weaknesses carry real operational consequences. Here’s a look at where transparency efforts are falling short and what would make the biggest difference.

US Department of Labor announces $76M available to advance employment readiness for American Indians, Alaska Natives, Native Hawaiians – The U.S. Department of Labor today announced the availability of approximately $76 million in funding to advance employment and training assistance to American Indians, Alaska Natives, and Native Hawaiians. These grants reflect the Trump administration’s commitment to build education-to-career pipelines that help job seekers and meet the workforce demand. Funding will support American Indian, Alaska Native, and Native Hawaiian adults and youth develop academic, occupational, and literacy skills. The grants also help individuals become more competitive in the workforce and equip them with entrepreneurial skills needed for successful self-employment.  The department will also award Supplemental Youth Service grants to support summer and year-round employment and training activities for American Indian, Alaska Native, and Native Hawaiian youth, ages 14 to 24, residing on or near a reservation and in Oklahoma, Alaska, and Hawaii. This population includes youth in high school, those without a high school diploma, and young people who need to acquire basic skills. 

Small businesses are navigating one of the most turbulent contracting environments in decades – The Small Business Administration Office of Advocacy has released its first‑year report examining how small businesses are responding to rapid shifts in federal contracting and regulatory policy. The findings highlight both strain and adaptation as firms adjust to changing rules and agency practices.

IBM Pays $17 Million to Resolve Allegations of Discrimination Through Illegal DEI Practices – Today, Acting Attorney General Todd Blanche announced the first False Claims Act resolution secured under the Civil Rights Fraud Initiative, which he launched in May 2025.  International Business Machines Corporation (IBM) has agreed to pay the United States $17,077,043, inclusive of civil penalties, to resolve allegations that it violated the False Claims Act by failing to comply with anti-discrimination requirements in its federal contracts due to practices the United States contends discriminated against employees and applicants for employment because of race, color, national origin, or sex.  Most federal contracts contain provisions that require contractors to comply with anti-discrimination requirements as to employees and applicants for employment.  As a condition to being a federal contractor, the company must certify that it will not discriminate against an employee or applicant for employment because of race, color, national origin, or sex and must further certify that it will take steps to ensure that applicants are employed, and employees are treated during employment, without regard to race, color, national origin, or sex. The settlement resolves allegations that IBM failed to comply with these requirements and knowingly maintained practices that the United States contends were discriminatory employment practices.

The RFO highlights the need for evergreen contracting – A highlight of the Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) is the revised competitive ordering procedures under the Federal Supply Schedule (FSS) program. The RFO, consistent with the General Service Administration’s (GSA’s) exclusive statutory authority for the FSS program, transferred the ordering procedures from FAR 8.4 to General Services Acquisition Regulation (GSAR) Subpart 538.7100. The revised FSS ordering procedures are now written in plain, clear and concise language. The overly complex ordering guidance, especially for Blanket Purchase Agreements (BPA), has been eliminated while, at the same time, the RFO clarifies the underlying statutory competition requirements for FSS task and delivery orders. The RFO also eliminated redundant portions of FAR 8.4 already addressed in FSS contract clauses, reducing the word count from 9,449 in the old FAR 8.4 to 2,363 in GSAR 538.7100. The overhaul of the FSS ordering procedures will enhance competition, promote innovation and drive best-value commercial solutions to meet customer agency needs.

OPPORTUNITIES:

USAF RFI: Enterprise Hybrid SATCOM Connectivity Solutions.
DOD RFI: Distributed LVC Integration and Cross-Facility Connectivity Architecture.
NGA RFI: Astrea (a follow-on to the Spectrum contract).
DOC RFP: AI Exports Program.
NASA RFI: ARMD Aeronautics Flight Accelerator.
Pre-solicitation: $1.4B R&D Engineering (RETS) IDIQ.
GSA RFI: SmartPay Government Charge Card Modernization.
DHA RFP: $300M Health IT Deployment IDIQ.
USAF RFI: Modernizing Enterprise IT Service Management.
NATO RFI: NSATU Level 1 & Level 2 Support Service Outsourcing.
DOJ RFI: AI-driven Supply Chain Analytics Platform.
HUD RFI: Technology Transformation Next Generation Program.
USDOT RFI: Procurement System Review (PSR).

BID PROTEST DECISIONS:

B-423993,B-423993.2, Effective Communication Strategies, LLC; Corps of Engineers, February 18, 2026
https://www.gao.gov/products/B-423993,B-423993.2

Effective Communication Strategies, LLC (ECS), a small business of Rapid City, Michigan, protests the award of a contract to Export 220Volt, Inc., a small business of Houston, Texas, under request for quotations (RFQ) No. W912DY-25-Q-A101, which was issued by the Department of the Army, Corps of Engineers, for replacement appliances at multiple U.S. Navy installations. The protester contends that the agency provided the protester insufficient time to respond to substantive amendments and technical review feedback.  GAO sustained the protest.

FREE TRAINING:

Upcoming Presentations from PilieroMazza:

TRAINING: Labor Rules & Regulations: Federal Market Compliance, April 15, 2026, Sarah L. Nash

PM WEBINAR: The New DEI Crackdown: What Federal Contractors Must Do Now, April 22, 2026, Sarah L. NashMatthew E. FeinbergLauren Brier

WEBINAR: Future-Proofing Your Contracts: Legal Compliance Updates for Government Contractors, April 23, 2026, Nichole D. Atallah

TRAINING: ABCs of the SCA: Critical Path Service Contract Act Training for Government Contractors, April 28-30, 2026, Nichole D. AtallahSarah L. Nash

TRAINING: Small Business Contracting & Subcontracting, April 15, 2026, Eric Valle

WEBINAR: Tariffs in Government Contracting, April 23, 2026, Jacqueline K. Unger

WEBINAR: Using JVs to Win Work with GSA and Beyond, April 30, 2026, Meghan F. Leemon

TRAINING: SBA Regulatory Updates, May 19, 2026, Eric A. Valle

WEBINAR: The Buy American Act and Trade Agreements Act, May 28, 2026, Jacqueline K. Unger

WEBINAR: Don’t Leave Money on the Table: Unlocking Federal Contract Disputes to Increase Cost Recovery, April 3, 2026, Lauren BrierJonathan “Jon” R. Neri

PM WEBINAR: Contract Claims 101: The Fundamentals of Contract Administration Disputes, April 16, 2026, Josie FarinelliAbigail “Abby” FinanKelly A. Kirchgasser

TRAINING: Legal Considerations: How Best to Structure Your Company as a Federal Contractor, April 14, 2026, Isaias “Cy” Alba, IV

PM WEBINAR: Contract Basics for Entrepreneurs: The Contracts You Need in Your Legal Toolkit as You Scale Your Business, May 7, 2026, Kristen Centre