TWIG-C™ – March 16, 2026

Mar 16, 2026 | TWIG-C™

GOVCON INSIGHTS AND INFORMATION:

GSA MAS Refresh #31: Key Changes and Updates Every Contractor Should Know – The General Services Administration (GSA) announced back in January that Multiple Award Schedule (MAS) Solicitation 47QSMD20R0001 – Refresh # 31 is expected to be issued in March/April 2026. Refresh #31 will introduce significant changes, including new Artificial Intelligence (AI) requirements alongside the expansion of the Transactional Data Reporting (TDR) pilot program. Government contractors should review the proposed updates (summarized below) and submit comments to GSA on Refresh #31 by March 20, 2026, to stay ahead of compliance obligations and prepare for future offers, new AI requirements, and the expanded TDR program.

How DoD’s own budget process keeps the military on the wrong side of the ‘valley of death’ – In fiscal year 1956, the Army didn’t ask Congress for a single dollar in its procurement budget. It didn’t need to. Back then, DoD’s budget accounts were apportioned in incredibly broad lump sums, and the dollars didn’t expire. So the Army could simply use $5 billion in unspent funds left over from the Korean War for all of its equipping needs that year.

No Severance, No Non-Compete? Virginia Expands Its Non-Compete Restrictions – Virginia is poised to further expand its restrictions on employee non-competes. The Virginia legislature recently passed SB 170 (the “SB 170”), making employee non-competes unenforceable if an employer terminates an employee without cause and does not provide severance or other monetary compensation. This new requirement applies to non-competes for employees at all levels regardless of compensation. Failure to comply with SB 170 can lead to civil penalties and private rights of action with recovery of attorney fees and damages. SB 170 is headed to Governor Abigail Spanberger, who is expected to sign it.

Former U.S. Patent and Trademark Office Employee Agrees to Pay $122,480 to Resolve Conflict-of-Interest Allegations – Christine Tu, a former Patent Examiner for the U.S. Patent and Trademark Office (USPTO), has agreed to pay $122,480 to resolve allegations that she violated conflict-of-interest rules during the course of her employment with the USPTO.
Among other things, the Ethics Reform Act of 1989 prohibits executive branch employees from participating personally and substantially in particular matters that will affect their own financial interests. The settlement resolves allegations that, between October 2019 and November 2022, Tu worked personally and substantially on at least one patent application submitted by a company in which she had a disqualifying financial interest. In addition, the settlement resolves allegations that Ms. Tu reviewed more than 20 patent applications submitted by a company that was a commercial competitor of a company for which she owned more than $125,000 worth of stock. As part of the settlement, Tu has agreed to pay a civil penalty to resolve allegations that her conduct violated conflict-of-interest prohibitions for federal employees.

DoD to evaluate ‘external’ CMMC risks – The Government Accountability Office is recommending the Defense Department do a better job managing a range of “external factors” that could trip up the Cybersecurity Maturity Model Certification, or CMMC, program. GAO’s latest report is a reminder of how DoD has outsourced a large chunk of the contractor cybersecurity verification program. The CMMC program is intended to ensure defense contractors are following requirements for protecting sensitive DoD data on their networks. DoD just began including CMMC requirements in contracts late last year. GAO’s report on defense contractor cybersecurity found DoD has largely met the elements of having a “comprehensive strategy” for the CMMC program. But the auditor says DoD “has not systematically assessed and documented the external factors that could affect the department meeting its goals.”

Army Expands Use of Enterprise Contracts to Streamline Procurement – The U.S. Army is expanding its use of enterprise contracts to streamline procurement, promote competition and leverage enterprisewide buying power as part of efforts to modernize acquisition.
The Army’s push toward enterprise contracts reflects ongoing changes in how the service approaches acquisition and modernization. Reserve your seat at the Potomac Officers Club’s 2026 Army Summit on June 18 to hear from government and industry leaders discussing priorities, technology developments and other trends shaping the military service. The service said it has awarded 14 enterprise contracts in the past eight months, consolidating 118 separate agreements into unified vehicles and enabling the Army to achieve an 88 percent reduction in total contracts.

FAR UPDATES:

Federal Acquisition Regulation: Trade Agreements Thresholds – OFPP, DoD, GSA, and NASA (collectively referred to as the Federal Acquisition Regulatory Council, or FAR Council) are issuing a final rule amending the Federal Acquisition Regulation (FAR) to incorporate revised thresholds for application of the World Trade Organization Government Procurement Agreement and the Free Trade Agreements, as determined by the United States Trade Representative. Effective March 13, 2026.

Federal Acquisition Regulation; Federal Acquisition Circular 2026-01; Small Entity Compliance Guide – This document is issued under the joint authority of OFPP, DoD, GSA, and NASA. This Small Entity Compliance Guide has been prepared in accordance with section 212 of the Small Business Regulatory Enforcement Fairness Act of 1996. It consists of a summary of the rule appearing in Federal Acquisition Circular (FAC) 2026-01, which amends the Federal Acquisition Regulation (FAR). Interested parties may obtain further information regarding this rule by referring to FAC 2026-01, which is published elsewhere in the Rules section of this issue of the Federal Register. March 13, 2026.

OPPORTUNITIES:

USAF RFI: E-7A Aircraft Product Support Business Case Analysis.
Army RFI: TMC Program.
VA RFI: Telehealth, Scheduling, & Mobile Platform Services.
DHA Sources Sought: Facilities Enterprise FOB CADD Support.
DARPA RFP: Quantum Benchmarking Initiative Topic Stage A.
FAA RFI: NAS Cyber Information Security and Operations.
NATO RFIP: Agentic AI for Cognitive Warfare.
DOD, ODNI RFP: AI Evaluation Harness & Benchmark Framework.
Army RFI: Systems Engineering and Technical Assistance (SETA) Support.
USAF RFI: SBIR PH3 Space Integrated Modeling, Simulation (SIMSA).
NGA RFI: SHIELD 2.0.
FDIC RFI: Acquisition System Next Generation (AS NG).
VA RFI: RECOMPETE-eDiscovery: SaaS and Maintenance.
NOAA D-RFP: $8B Space-Based Environmental Monitoring (SBEM).

FROM THE FLORIDA APEX ACCELERATORS:

Strict Compliance With Proposal Formatting Instructions:

Recent GAO bid protest decisions make one thing clear: strict compliance with proposal formatting instructions is not optional. Even minor deviations—such as using an unapproved font, exceeding page limits, adding an extra cover page, including prohibited text in a logo, or submitting pricing in the wrong format—can result in outright exclusion from the competition, regardless of the proposal’s technical merit. These cases highlight the risks of making assumptions about formatting requirements and underscore the importance of carefully following the solicitation’s instructions—or seeking clarification through formal Q&A—to avoid preventable disqualification. Don’t let a preventable formatting mistake cost you a contract opportunity. Read the full blog post to see what these recent GAO decisions mean for your proposal strategy, and how to protect your next submission.

Federal Contract Awards in FY25: Spending Patterns Across Agencies and Industries:

In FY25, the federal government spent $833.83B — an increase of $50B or 7.47% — over FY24 when federal spending reached $774B. While the early trends suggested FY25 spending would track closely to FY24, and that DOGE-related cuts would not materially reduce overall spend, the final figure exceeded expectations, pushing the federal contracts awarded to a new peak of $833.8B. To read more about how the FY2025 spending patterns looked across agencies visit govspend.com/blog.

Incumbent Not Entitled to Special Re-Compete Notice:

An incumbent contractor is not entitled to any special treatment when it comes to notification of a re-compete of the incumbent contract. In a recent bid protest decision, the GAO held that when an agency followed FAR procedures by posting a re-compete solicitation on System for Award Management (SAM), the agency was within its rights not to provide the incumbent contractor with any additional notice of its decision to re-compete. The incumbent, GAO determined, was legally on notice of solicitations posted on SAM—just like everyone else. Read more about the decision.

Can Government Contractors Use Agency Logos and Seals?

Visit a federal government contractor’s website, read its brochures and capability statement, or follow its social media accounts, and you may see the logos and seals of the contractor’s federal government customers prominently displayed. But although contractors’ use of agency logos and seals is widespread, it’s often prohibited under agency policy, federal law, or both. Read the full article here to understand when using agency logos and seals could put your company at legal risk.

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:

Counting What Matters: Small Business Contracting Goals & Metrics

FREE TRAINING:

Q&A Session: Contract Award Searching in SAM.gov (from GSA)

Upcoming Presentations from PilieroMazza:

SEMINAR: Legislative & Regulatory Year In Review and Advisory Forum, March 17, 2026, Jon Williams

CONFERENCE: Essential Legal Updates for Businesses Entering the GovCon Industry, March 17, 2026, Josie Farinelli

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

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

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

TRAINING: Labor Rules & Regulations: Federal Market Compliance, March 18, 2026, Sarah L. Nash

CONFERENCE: Ins and Outs of the Service Contract Act, March 23, 2026, Nichole D. Atallah