TWIG-C™ – April 27, 2026

Apr 27, 2026 | TWIG-C™

GOVCON INSIGHTS AND INFORMATION:

Changes in the government procurement arena – The discussion focuses on the multiple changes on the proposal and bidding side of the market.

Topics include

LPTA and HTRO methods of procurement, where each fits and why/when you need one of the other
Understanding that you need to influence before the RFQ goes out
The need for differentiated visibility, defining your area of expertise in terms that resonate with the customer
Operating in an environment with 40% fewer contracting officers and why that makes visibility, being known, more important

5 Things GovCons Should Know About Changing Procurement Regulations Across Government – The federal procurement landscape is undergoing a major shift to streamline and accelerate the acquisition and implementation of advanced capabilities that could enhance the delivery of government services or support mission execution. At the heart of these changes is the Revolutionary Federal Acquisition Regulation Overhaul, a multi-year initiative mandated under the Restoring Common Sense to Federal Procurement executive order. The FAR Overhaul aims to reduce regulatory burdens for the government contracting industry and ensure the efficient use of taxpayer dollars. At the same time, the Department of War has started its multi-phase rollout of Cybersecurity Maturity Model Certification, or CMMC, which requires contractors to adopt measures to secure federal contract information or controlled unclassified information.

Is SBA moving the small business contracting goal posts? – Nearly seven months into the fiscal year, the Small Business Administration is considering moving the small business contracting goal posts for agencies. In a document sent to agencies in March, SBA detailed new factors it will consider as it grades agency efforts to contract with small businesses. Among the major changes expected are a focus on contracting with veterans, both service-disabled and non-service disabled, fewer sole source 8(a) contracts, changing the name of the small disadvantaged business category to economically disadvantaged to include SDBs as well as veteran-owned firms, efforts to root out fraud and how the agency is providing “competitive value to the taxpayer.”

Agencies must defend decisions for not buying commercial items – For perhaps the first time since the Federal Acquisition Streamlining Act became law in 1994, the Office of Management and Budget is holding agencies’ feet to the fire for buying commercial items. What’s different today than at any other time over the last 30 years is OMB actually wants agencies to prove they are meeting the spirit and intent of FASA.

Past Performance as a Subcontractor: What Are the Evaluation Rules? – “The protester argues that the solicitation’s requirement that past performance be from efforts that the offeror has ‘performed as a prime contractor’ did not necessarily require that the offeror was the actual prime contractor on the effort.” When you read a sentence like that in a GAO bid protest decision, you don’t have to be Nostradamus to predict that the protest will end up in the “denied” pile. But while the outcome of the recent GAO case in which this sentence appeared was predictable, the case highlights a question that prospective government contractors often ask: “when I am bidding as a prospective prime contractor, does a federal government agency have to consider the past performance I earned as a first-tier subcontractor?”

Commerce goes direct to hyperscalers with $4.1B cloud pact – The Commerce Department is planning a 10-year, $4.1 billion blanket purchase agreement for cloud computing capabilities and only the big hyperscalers need apply. In a Sam.gov notice posted Thurday, the department said the BPA will only be open to native hyperscale cloud services providers. The department said it is going with a direct to CSP strategy because of the “highly specialized technical requirements, including massive compute elasticity (25,000+ concurrent vCPUs), proprietary 100+ tbps (terabits per second) global backbones, and specific hardware density for AI/ML, and weather modeling.”

FAR UPDATES:

FAR Updates Trade Agreement Act Thresholds – The The Trade Agreements Act (TAA) and its companion, the Buy American Act (BAA), both set policies for a preference for increased domestic purchases by the federal government and its contractors. However, the TAA is designed as kind of a counterweight to the BAA. The BAA (passed in 1933), “the first of the major domestic content restriction laws, requires federal agencies to apply a price preference for ‘domestic end products’ and use ‘domestic construction materials’ for covered contracts performed in the United States.” So, the BAA encourages use of US-produced goods. The TAA, on the other hand, waives some of those requirements in favor of certain countries. The TAA permits waiver of BAA “domestic content restrictions” with respect to certain “countries that have trade agreements with the United States.” So, for “covered end products or construction materials imported from a designated country” where they are manufactured or transformed “are treated as domestic end products or materials for purposes of the BAA.” A recent change to the FAR updates the thresholds at which the TAA becomes applicable to federal procurements. Because these thresholds can change, it can have an impact on which contracts are applicable to the TAA versus the BAA.

The Federal Acquisition Regulatory Council has released updates to Federal Acquisition Regulation (FAR) model deviations to implement Executive Order (E.O.) 14398, Addressing DEI Discrimination by Federal Contractors, dated March 26, 2026.

In accordance with issued FAR Council implementing guidance, the following RFO updates were posted on April 20, 2026:

RFO Part 9 – Contractor Qualifications – FAR 9.4 has been updated to incorporate failure to comply with the requirements of the clause at 52.222-90, Addressing DEI Discrimination by Federal Contractors as a cause for debarment or suspension.
- Implementation Support: Practitioner Album: FAR Part 9

RFO Part 12 – Acquisition of Commercial Products and Services – Table 12-3 has been updated to include the clause at 52.222-90, Addressing DEI Discrimination by Federal Contractors.
- Implementation Support: Practitioner Album: FAR Part 12

RFO Part 22 – Application of Labor Laws – New subpart 22.22 – Addressing DEI Discrimination by Federal Contractors to include definitions at 22.2201 and policy at 22.2202.
- Implementation Support: Practitioner Album: FAR Part 22

RFO Part 52 – Solicitation Provisions and Contract Clauses – Creates the new clause 52.222-90, Addressing DEI Discrimination by Federal Contractors (APR 2026), and adds this clause to the table of clauses required to be flowed down to subcontracts for commercial products or commercial services in clause 52.244-6 (APR 2026).
- Implementation Support: Practitioner Album: FAR Part 52

OPPORTUNITIES:

USAF RFI: Mobile Command and Control Systems.
USN RFI: LCS MRG RENK Engineering Support.
USAF RFI: Accelerated Devt. of the 2nd Gen Anti-Jam Tactical UHF Radio for NATO.
Senate RFI: Cybersecurity Support Services.
VA RFI: Enterprise Service Desk Managed Contact Center Infrastructure.
USAF RFI: Offensive Cyber Depot Operations & Sustainment.
USN RFI: LCS MRG RENK Engineering Support.
CENTCOM RFI: Transforming in Contact (EXTiC) 26-2.
NAVSEA RFI: Mine Warfare (MIW) and Surface Mine Countermeasures (SMCM) Design Agent (DA) TDA ISA FMS Support.
DARPA RFP: “Deep Thoughts” Autonomous Underwater Drones.
DOE RFI: eBeam Systems.
DOJ RFI: ATR IT Modernization: Data Analytics Solution.
Space Force Seeks Industry Input on 25 High-Priority NSSL Phase 3 Launch Missions