TWIG-C™ – May 26, 2026

May 25, 2026 | TWIG-C™

GOVCON INSIGHTS AND INFORMATION:

DoD Proposes Implementing Rule for FOCI Review Expansion for Unclassified Contracts – On May 7, 2026, DoD published a proposed rule for Mitigating Risks Related to Foreign Ownership, Control, or Influence (FOCI Rule) under Title 48 of the Code of Federal Regulations. The FOCI Rule seeks to implement the directive for expanded FOCI and beneficial ownership disclosures under Section 847 of the FY2020 National Defense Authorization Act (see December 2025 GT Alert) and DoD Instruction 5205.87. The FOCI Rule would also amend DFARS by creating part 240 – Information Security and Supply Chain Security – and would add a new solicitation provision and contract clause. The proposed FOCI Rule would apply broadly to unclassified contracts or subcontracts exceeding $5 million. Contracts at or below the simplified acquisition threshold would be exempt. Additionally, contracts using Federal Acquisition Regulation (FAR) Part 12 for commercial products and services, including commercially available off-the-shelf items, would be exempt unless a “designated senior DoD official” determined otherwise. DoD estimates that 37,740 contractors (and 21,511 small businesses, which make up 57%) would be impacted by the FOCI Rule, which is now subject to a 60-day public comment period.

White House seeks federal spending data on dozens of nonprofit organizations –
The White House is seeking detailed spending information on federal dollars going toward dozens of nonprofit organizations, according to a memo obtained by Federal News Network. The memo, which the Office of Management and Budget circulated to executive branch agencies on May 13, calls on all federal departments and agencies to submit agency-level spending data related to a targeted list of 49 nonprofit organizations.
The organizations named in the memo, reviewed by Federal News Network, do advocacy work supporting diversity, equity and inclusion (DEI); the LGBTQ+ community; immigrants and refugees; civil rights and legal aid; environmentalism; and international and humanitarian aid. The list contains nonprofit groups such as the American Civil Liberties Union, National Urban League and U.S. Committee for Refugees and Immigrants.

House Small Business Committee Unanimously Advances “Rule of Two” Bill Toward Full House Vote – In a significant development for the small business federal contracting community, the House Small Business Committee unanimously approved an amended version of H.R. 2804, the Protecting Small Business Competitions Act of 2025, advancing legislation that would codify the longstanding Rule of Two into statute. The bill now moves to the full House of Representatives for consideration. This milestone marks a major step toward placing one of the federal procurement system’s foundational small business protections on firmer legal footing. The Rule of Two helps ensure small businesses have meaningful access to federal contracting opportunities, and codifying it would provide greater certainty and protect those opportunities from being weakened or eliminated through future regulatory changes. Despite this positive step, passage is not guaranteed, and continued industry advocacy will be essential to ensuring the bill becomes law.

Small Businesses Move to Defend Federal Program that Supports Historically Disadvantaged Entrepreneurs – Two small businesses moved to intervene in federal court to defend the longstanding federal 8(a) Business Development program after the Trump-Vance administration signaled it may refuse to defend the program in a legal challenge – Revier Technologies, Inc. v. SBA – that seeks to dismantle key protections and opportunities for historically disadvantaged entrepreneurs and small business owners. In addition to the motion to intervene, the small businesses filed a motion to dismiss the case.

Small Business Set-Asides in FY 2026: What the Data Signals for What Comes Next – The federal small business market is in a state of flux. With sweeping SBA recertification rules, increased scrutiny on the 8(a) program and shifting agency priorities, the landscape has been fundamentally reshaped, tightening the compliance requirements small businesses must meet to remain competitive as the number of prime contract positions continues to shrink. These shifts are already visible in current acquisition trends and are influencing corporate decisions and investments. Across agencies and programs, these developments point to a clear pattern in the evolution of the federal market. In this article, I’ll outline the regulatory, market and procurement changes driving this evolution, and show how small firms must adapt their growth, compliance and go-to-market strategies to stay competitive.

Revolutionary FAR Overhaul: When Does It Apply? – The government rewrote the entire Federal Acquisition Regulation in 2025 in a process called the Revolutionary FAR Overhaul. One might assume, then, that on a specific date last year, the “RFO” FAR began to apply to every federal solicitation and contract. It’s not so simple. Because of the unusual manner in which the Revolutionary FAR Overhaul was implemented, there is no single, bright-line date on which the Revolutionary FAR Overhaul applied to all solicitations and contracts government-wide. Instead, different agencies have adopted different pieces of the RFO on different dates. That means that a solicitation or contract may be governed by the “base” FAR, the RFO FAR, or a Frankenstein-esque combination of both.

These RFPs show acquisition reform is more than just policy – Three recent solicitations offer an interesting glimpse into the Trump administration’s influence on federal procurement. From the overhaul of the Federal Acquisition Regulations to the push for consolidation and centralization to the focus on modernizing back office systems, these three requests for proposals demonstrate how agencies are implementing and accepting the Office of Management and Budget’s prioritization of reforming federal technology and acquisition management. The one thing that these solicitations also remind us all about is they mostly are hidden behind the federal firewall called eBuy. I will spare you my typical soap box rant, but here is previous tirade in case you want to join me in this crusade for more transparency.

The administration is leaning on the Defense Production Act to shape supply chains through federal support, not mandates – The latest use of the Defense Production Act expands federal tools to support domestic energy capacity across the supply chain. It does not compel action, but it opens a path for financing and program support. Whether that translates into projects will turn on agency follow-through.

Two Defense Contractors Arrested for Bribery and Major Fraud Conspiracy Scheme Affecting Department of War Technology Innovation Contracts – the Justice Department announced criminal charges against Leonard Pick, 62, of Palm Beach Shores, Florida, and Brian Kent, 59, of Tampa, Florida, for orchestrating a bribery and major fraud conspiracy that corrupted the competitive procurement process for a Department of War technology innovation lab in the Pacific. The defendants’ alleged conduct specifically affected the construction and operation of the U.S. Army Pacific Command’s Hawaii-Pacific Innovation Campus, which was intended to be a hub for testing new technologies for the Department of War.

Ending Discrimination in Government Contracting Act Proposes to Eliminate Preferences for 8(a) and WOSB Firms – On April 27, 2026, Senator Mike Lee (R-UT) and Congressman Glenn Grothman (R-WI) introduced companion bills called “Ending Discrimination in Government Contracting Act.” The bills (H.R. 8511) and (S. 4390) seek to eliminate federal contracting preferences for “socially and economically disadvantaged individuals” and “small business concerns owned and controlled by women,” essentially gutting the statutory bases for the Small Business Administration’s Woman-Owned Small Business (WOSB) and 8(a) Business Development Program (the 8(a) Program). Following President Trump’s March 26, 2026, Executive Order titled “Addressing DEI Discrimination by Federal Contractors,” these two bills are the latest efforts to remove contracting preferences based on race, ethnicity, and sex. Both bills have been referred to committee and are currently under review. Government contractors should monitor these developments closely and consider contacting their Members of Congress if they wish to advocate for these small business programs.

New whistleblower rules encourage a nation of paid informants – The new whistleblower program is the latest sign of a broader shift in American enforcement policy. Agencies are increasingly turning to whistleblower programs as enforcement tools, moving from a system focused primarily on protecting those who report wrongdoing to one that pays for information. This trend did not begin with this network. Since 1963, the False Claims Act has allowed qui tam whistleblowers to sue on behalf of the government and collect 15 percent to 30 percent of the recovery.

OPPORTUNITIES:

USN RFI: Commercially-Based Supersonic Aerial Target Solutions.
NATO RFI: Integrated Event Operations (IEO) Platform.
NGA RFI: HATTERAS.
NASA RFI: Private Sector Partnerships (Astrobiology, Planetary Protection, and Space Biology).
Army RFI: SMS Technical Support Services and Equipment.
USN RFI: Acquisition Support Services.
USPTO RFI: Piller UPS System Engineering Assessment.
DOE RFP: Records Digitization Services.
NASA Issues Draft Solicitation for Landsat 10 Spacecraft Contract