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Understanding the Proposed Updates to Organizational Conflict of Interest Rules

On January 15, the Department of Defense, GSA, and NASA published proposed rules that would implement the Preventing Organizational Conflicts of Interest in Federal Acquisition Act. The Act was enacted on December 27, 2022. It directs the Federal Acquisition Regulatory (FAR) Council to:

  • update regulatory definitions related to specific types of organizational conflicts of interest (OCIs), including unequal access to information, impaired objectivity, and biased ground rules;
  • provide updated guidance and illustrative examples related to relationships of contractors with public, private, domestic, and foreign entities that may result in OCIs; and
  • provide illustrative examples of situations related to the potential for OCIs.

The proposed changes implement the Act by moving OCI regulations to a new subpart, FAR part 3, and substantially revising and clarifying current OCI regulations.

The focus of the proposed rule is to update and strengthen policies to prevent OCIs in federal contracting.

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Pentagon aims to accelerate acquisition of new tech through software-contracting change

Buyers must default to rapid-acquisition processes long used by DIU, SecDef memo orders.

The Pentagon must default to rapid acquisition processes when buying software, from business systems to weapons components, the defense secretary said in a Thursday memo. The move is a “big deal,” one expert told Defense One, because it will push the Defense Department to stop spending considerable money and time trying to build its own software and instead go to the marketplace for products that might already exist.

“While the commercial industry has rapidly adjusted to a software-defined product reality, DoD has struggled to reframe our acquisition process from a hardware-centric to a software-centric approach,” Defense Secretary Pete Hegseth wrote in the March 6 memo. “Software is at the core of every weapon and supporting system we field to remain the strongest, most lethal fighting force in the world.”

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FSRS.gov to Retire This Week: How-To Videos Available, Register Now for Weds Training

The General Services Administration will retire FSRS.gov the evening of March 6, 2025. This means that the system will be unavailable and no new data can be entered into FSRS.gov.  Subaward reporting will then become available in SAM.gov on March 8, 2025.  

We advise the following actions:

• FSRS.gov users who already have a SAM.gov account should take action now to connect their two accounts.
• FSRS.gov users who do not currently have a SAM.gov account should take action now to create a new account at SAM.gov.
• All users will need to be granted the correct role and permission in SAM.gov by their SAM.gov entity administrator before being able to access the new subaward reporting capabilities after March 8.

To help users prepare for the change, we are holding a live training session on Wednesday at 1:00PM EST to walk through what subaward reporting will look like in SAM.gov.  Register now for the March 5 training.

Additionally, GSA just posted two previous trainings and five how-to videos to the IAE playlist on GSA YouTube that users can access and watch now (including a bulk upload training).

For the latest information about subaward reporting in SAM.gov and links to relevant information, please visit our information page on SAM.gov.

Pentagon seeks to shift $50B in planned funding to new priorities in FY26

Breaking Defense obtained a list of the 17 priority categories that are to be financially protected in FY26.

WASHINGTON — Secretary of Defense Pete Hegseth has ordered a review of the department’s fiscal 2026 budget plans in order to shift funds from legacy programs towards President Donald Trump’s priorities, including border security and the Iron Dome for America.

The goal: Find roughly $50 billion, or 8 percent of the FY26 plan, and reprioritize it.

“Secretary Hegseth has directed a review to identify offsets from the Biden Administration’s FY26 budget that could be realigned from low-impact and low-priority Biden-legacy programs to align with President Trump’s America First priorities for our national defense,” acting Deputy Secretary of Defense Robert Salesses said in a Wednesday night statement.

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Defense Logistics Agency FY2024 Annual Report

DLA’s Fiscal 2024 Annual Report is here!
Discover how DLA is transforming and closing the gaps in 2025 to continue to deliver the agile, adaptive and resilient support our warfighters expect and deserve.
What’s Inside?
✅ Strategic Plan 2025-2030: A call to action
✅ Key financial and acquisition metrics
✅ Service and CCMD support highlights

With operations in 48 states and 28 countries, DLA managed $52.6B in obligations and $47B in revenue in fiscal year 2024, placing us among the top 350 Fortune 500 companies.

https://www.dla.mil/Portals/104/Documents/Headquarters/AnnualReport/DLAFiscal2024AnnualReport7February2025.pdf

Secretary Hegseth’s Message to the Force

In regards to rebuilding the defense industrial base (DIB) and reforming the acquisition process:

“We will rebuild our military by matching threats to capabilities. This means reviving our defense industrial base, reforming our acquisition process, passing a financial audit, and rapidly fielding emerging technologies. We will remain the strongest and most lethal force in the world.”

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Executive Order on Strengthening and Promoting Innovation in the Nation’s Cybersecurity

Section 1.  Policy.  Adversarial countries and criminals continue to conduct cyber campaigns targeting the United States and Americans.  These campaigns disrupt the delivery of critical services across the Nation, cost billions of dollars, and undermine Americans’ security and privacy.  More must be done to improve the Nation’s cybersecurity against these threats.

Sec. 2.  Operationalizing Transparency and Security in Third-Party Software Supply Chains.  (a)  The Federal Government and our Nation’s critical infrastructure rely on software providers.  Yet insecure software remains a challenge for both providers and users and makes Federal Government and critical infrastructure systems vulnerable to malicious cyber incidents.  The Federal Government must continue to adopt secure software acquisition practices and take steps so that software providers use secure software development practices to reduce the number and severity of vulnerabilities in software they produce.

Sec. 3.  Improving the Cybersecurity of Federal Systems.  (a)  The Federal Government must adopt proven security practices from industry — to include in identity and access management — in order to improve visibility of security threats across networks and strengthen cloud security.

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Army Introduces Regulation on Small Business Programs

The regulation directs the secretary of the Army to establish an Office of Small Business Programs within the department and ensure that the director of SBP has sufficient resources to oversee the Small Business Program. The department’s principal officials should ensure that all requirements sent to contracting are free of restrictive requirements that hinder small vendors from performing as prime contractors. They should also solicit advice from small business professionals when conducting market research and identifying companies that can perform the work.

Under the new regulation, the assistant secretary of the Army for acquisition, logistics and technology should oversee the execution of the Small Business Innovation Research, or SBIR, and Small Business Technology Transfer, or STTR, programs; coordinate with the SBP director regarding the two programs; and share information on procurement opportunities, prize competitions and industry engagements.

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Defense Innovation Board Releases Two Studies on Scaling Innovation in Nontraditional Industry and Drone Manufacturing

Secretary of Defense Lloyd J. Austin III and Deputy Secretary of Defense Kathleen Hicks hosted the Defense Innovation Board (DIB) for its winter Board meeting in the Pentagon on January 13th, 2025.  Underscoring Secretary Austin’s commitment to defending the nation through innovation and modernization, the DIB, chaired by Michael R. Bloomberg, discussed its efforts to catalyze and empower defense innovation leaders within the DoD and the defense industrial base.  The Board presented its two latest studies on Scaling Nontraditional Defense Innovation and A Pathway to Scaling Unmanned Weapons Systems.

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DOD Releases List of Chinese Military Companies in Accordance with Section 1260H of the National Defense Authorization Act for Fiscal Year 2021

The Department of Defense released an update to the names of “Chinese military companies” operating directly or indirectly in the United States in accordance with the statutory requirement of Section 1260H of the National Defense Authorization Act for Fiscal Year 2021.  The People’s Republic of China’s (PRC) Military-Civil Fusion strategy supports the modernization goals of the People’s Liberation Army (PLA) by ensuring it can acquire advanced technologies and expertise developed by PRC companies, universities, and research programs that appear to be civilian entities.  Section 1260H directs the Department to begin identifying, among other things, Military-Civil Fusion contributors operating directly or indirectly in the United States.  The Department will update the list with additional entities as appropriate.

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