TWIG-C™ – April 20, 2026

Apr 20, 2026 | TWIG-C™

GOVCON INSIGHTS AND INFORMATION:

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. Visit this link to register for our webinar on this important topic for government contractors.

The SBIR restart won’t be easy – Congress passed a bipartisan bill to reauthorize the Small Business Innovation Research and Small Business Technology Transfer programs (SBIR/STTR) nearly six months after the programs’ authorization expired. President Donald Trump signed that legislation on April 13. Now, don’t expect federal agencies to simply flip a switch back to normal. They will inherit a backlog amid a shrinking contracting workforce. An analysis of the SBIR.gov award database, which contains all 219,000 awards issued since the program’s founding in 1983, shows the scale of disruption this funding lapse has caused, and where the restart pressure will hit hardest.

NIST Publishes Draft Cybersecurity Guidance for Small Businesses With No Employees – The National Institute of Standards and Technology has released a new draft guidance to help small businesses strengthen their cybersecurity posture amid increasing threats.
The Small Business Cybersecurity: Non-Employer Firms is tailored to businesses with no paid employees beyond the owner. The document provides critical information to enable non-employer firms, including single-member limited liability companies, sole proprietors, independent contractors and freelancers, to manage cyber risks. The agency is encouraging the public to review the document and share their feedback by May 14.

GSA Set to Fully Realize Benefits of Transactional Data Reporting – Good things take time and that’s no different when it comes to GSA’s Transactional Data Reporting requirement for its Multiple Award Schedule (MAS) program. This month, GSA established TDR as mandatory for all new MAS offerors and existing MAS contract holders via solicitation refresh 31. This action initiates full TDR implementation on MAS. This marks a major milestone. TDR is bringing government buying into a new era by driving procurement consolidation, helping our acquisition workforce, and ultimately saving taxpayer dollars.
TDR is how GSA gathers data on prices paid for products and services sold through MAS. It also removes the burden of traditional sales reporting and tracking practices for MAS contractors, while enhancing data capabilities to improve service and reduce costs to the government. This change will also significantly reduce administrative burden for our acquisition workforce. More importantly, it will eliminate many repetitive steps, freeing up employees to focus on more meaningful and impactful work, such as negotiating better prices.

FedRAMP 20x – Major Overhaul Announced to Streamline the Security Authorization Process for Government Cloud Offerings – On March 24, 2025, the Federal Risk and Authorization Management Program (“FedRAMP”) announced a major overhaul of the program, which is being called “FedRAMP 20x.” The FedRAMP 20x announcement stated there are no immediate changes to the existing authorization path based on agency sponsorship and assessment against the FedRAMP Rev 5 baseline.[1] However, once the initiative kicks off, we expect major changes to speed up and streamline that authorization path that likely will be welcomed by industry partners and cloud service providers participating in the program.

DOJ Resolves First DEI-Related False Claims Act Matter with IBM for $17 Million – On April 10, 2026, the Department of Justice (“DOJ”) announced the first False Claims Act (“FCA”) resolution secured under its Civil Rights Fraud Initiative. The settlement resolves allegations that International Business Machines Corporation (“IBM”) violated the FCA “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,” and requires IBM to pay the federal government over $17 million. This is the first settlement of an FCA matter based on a contractor’s diversity, equity, and inclusion (“DEI”) initiatives.

Back to Basics: The Two-Year Rule – Something we get asked about a lot with regards to joint ventures is the two-year rule (not to be confused with the “Rule of Two,” which concerns contract set-asides). We have explored this rule in the past on a few occasions, however, it has been a little while since the last such post and it’s been a perennial issue for contractors that we talk to. As such, it would be helpful to have a refresher on this rule, which may help clear up some of those questions.

OPPORTUNITIES:

DISA RFI: Defense Research and Engineering Network.
DOD RFI: Information System Contingency Plans Generation.
AFRL AMAC cancellation: Solicitation withdrawn with no evaluations or awards.
NRO seeks industry partners to accelerate ISR.
NASA RFI: ARMD Aeronautics Flight Accelerator.
VA RFI: Data Monitoring and Sensing – Structured Data.
USAF RFP: COSMOS.
USAF RFI: Large Aircraft Threat Sensing, Cueing Capabilities, Tech Devt.
NGA RFI: Aeronautical Mobile Application (AMA).
VA RFI: Connectivity & Collaboration Services: NEDIIS.
NSF RFP: Integrated Data Systems & Services Program.
NOAA D-RFP: NESDIS Consolidated Antenna, Ground Systems Services.
DOE announces funding opp for Critical Minerals, Materials Accelerator.
NIWC Atlantic Issues $250M Solicitation for USCG Shipboard C5I Support

TIPS FROM THE FLORIDA APEX ACCELERATORS:

Understanding and Complying with the Berry Amendment
The Berry Amendment is a federal law (10 U.S.C. 4862) that prohibits the Department of War (DoW) from purchasing certain goods unless they were grown, reprocessed, reused, or produced in the United States. Covered items include, but are not limited to, food, clothing, tents, tarpaulins, natural fiber products, hand tools, and American flags — with the full list defined in DFARS 225.7002-1. The Berry Amendment is notably stricter than similar laws such as the Buy American Act and the Trade Agreements Act, allowing no price-based waivers and granting no foreign country-equivalent status, though limited exceptions exist for contracts under $200,000 (excluding American flags and certain footwear), emergency acquisitions, and perishable food purchases for personnel stationed abroad. Contractors can identify Berry Amendment-covered contracts by looking for one of three DFARS clauses (252.225-7012, 252.225-7015, or 252.225-7006) in the solicitation or contract. Failure to comply can carry serious consequences, including False Claims Act liability and contract termination. Learn more about the Berry Amendment and how to stay compliant.

Department of War (DoW) Launches LYNX to Help Businesses Enter and Compete in Defense Markets

The Department of War (DoW) Office of Small Business Programs (OSBP) announced the launch of LYNX, a new digital platform designed to strengthen supplier readiness, improve visibility into business capabilites, and expand participation across the Defense Industrial Base. Registration is now open at https://www.lynxconnect.io for businesses seeking to connect with mission-aligned partners and opportunities. Businesses begin by creating a company profile and completing an initial assessment to establish a readiness baseline and identify next steps.

GSA Proposes New SAM Certification Language for Federal Funding Recipients Addressing DEI, Immigration, and National Security

Contractors may soon be required to complete new certifications to register or re-register in the System for Award Management (SAM). The General Services Administration, which operates the SAM system, has proposed new SAM registration certifications requiring federal financial assistance recipients to attest that they comply with federal anti-discrimination laws (including those covering DEI programs), do not facilitate illegal immigration, and do not fund activities that threaten national security. Read the full analysis of GSA’s proposed SAM certification requirements.

Solicitation’s Page Limits Applied to Proposal Revisions

When an agency opens discussions and accepts revised proposals, contractors shouldn’t assume the solicitation’s original formatting rules no longer apply — a recent GAO decision confirmed that page limits carry through to Final Proposal Revisions unless the solicitation is formally amended. In this case, a contractor’s safety narrative grew from two pages to four during revisions, the agency refused to consider the extra pages, and the bid was ultimately rated unacceptable and eliminated from award. Read about why solicitation page limits don’t disappear when revised proposals are accepted

GSA’s New CUI Requirements: What Government Contractors Need to Know
The GSA has introduced a new compliance framework that contractors and other nonfederal entities are required to implement in order to handle Controlled Unclassified Information (CUI). The new requirements will affect thousands of federal contractors and could be incorporated into solicitations and applied to new awards at the contracting officer’s discretion. Read about the GSA’s new CUI requirements.

GSA Signals Enhanced Focus on Contractor Cybersecurity Practices: What You Need to Know About GSA’s New CUI Guide
While CMMC is a DoD-only program, publication of the new GSA CUI guide signals that contractors that process, store, or transmit CUI under civilian agency contracts should expect heightened scrutiny, formal assessments, and continuous monitoring obligations. Read about the GSA’s new CUI guide.

FREE TRAINING:

Leveraging Your NAICS Code to Your Strategic Advantage – Your NAICS code is more than a box to check on a registration form. It’s a strategic asset that shapes how the government finds you, evaluates you, and awards contracts to you. Yet most businesses treat it as an afterthought. Join Jon Barker, VP of Pricing at Strategic Growth Partners, Steve Koprince, former GovCon attorney and Educator at Govology, and Chris Riddick, director of partnerships at GovBrew, for “Leveraging Your NAICS Code to Your Strategic Advantage,” a free webinar on April 22 at 1 PM ET / 1 PM CT. In this webinar, we’ll break down how federal agencies and prime contractors actually use NAICS codes to search, sort, and select vendors. We will also show you how to use that knowledge to sharpen your competitive positioning in the marketplace.

GovCon Roundup Live is a free monthly webcast hosted by Carroll Bernard and Steven Koprince of Govology. The webcast covers policy changes, legislative updates, and industry shifts that signal strategic opportunities for contractors to pivot, reposition, and stay one step ahead. Learn more about GovCon Roundup Live and register to attend future live sessions (with the opportunity for live Q&A).

Recent GovCon Roundup Live webcasts include:

From Morrison Foerster:

ABA Small Business Committee Judges Panel, Apr 21, 2026, 04:00 PM – Please join us for a panel discussion hosted by the American Bar Association Small Business & Other Socioeconomic Programs Committee. The program will feature distinguished jurists from the Small Business Administration’s Office of Hearings and Appeals, the U.S. Court of Federal Claims, and the Government Accountability Office, sharing insights on significant cases involving small businesses in the past year, as well as practical considerations about practicing before these esteemed forums.

Panelists
•             Judge Christopher Holleman, SBA Office of Hearings and Appeals
•             Judge Stephen Schwartz, U.S. Court of Federal Claims
•             Glenn Wolcott, Government Accountability Office
Moderators
•             Ben Smith, Associate, Holland & Knight
•             Alissandra McCann, Associate, Morrison Foerster

Upcoming Presentations from PilieroMazza:

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

CONFERENCE: Small Business Panel: Navigating Today’s Marketplace Together, May 12, 2026, Isaias “Cy” Alba, IV

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

PM WEBINAR: The New DEI Crackdown: What Federal Contractors Must Do Now, April 22, 2026, Sarah L. Nash, Matthew E. Feinberg, Lauren 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. Atallah, Sarah L. Nash

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