GAO Reminds Agencies that “Less Favorable” Doesn’t Mean “Ignored:” A Past Performance Lesson from a Recent VA Protest
If your company is one of the many that relies on CPARS reports and past performance ratings to win federal work, a recent GAO decision is worth five minutes of your time. It doesn’t involve a dramatic scandal or an agency acting in bad faith. It’s something certainly more common and arguably more useful: an agency that set up a reasonable-sounding evaluation shortcut that didn’t actually match what […]
No Place Like Home: The Need for Unique Contractor Addresses in the Wake of a Fraud Crackdown
Partially in response to reports on federal benefit and healthcare fraud, the current administration established a White House Task Force to Eliminate Fraud, led by the Vice President. One area of particular concern to the government is home health care fraud. In particular, fictitious organizations bill the government for services never provided. One key indicator […]
The New Rules of Federal Government Contracting
I have spoken at many conferences.  One thing I learned is that if you are the final speaker, let people out early if there is a cocktail hour.  So, on the cusp of a three-day weekend, I will be brief.  At Centre we have kept you informed on the fast-changing world of government contracting every week through our […]
Semiconductor Manufacturing Equipment: BIS’s Shift to More Aggressive Enforcement
Historically, the semiconductor sector has been subject to broad export-control rulemaking by the Bureau of Industry and Security (BIS). Recently, however, the agency has shifted toward a more aggressive enforcement phase, particularly targeting semiconductor manufacturing equipment (SME) companies. For SME companies, the issue is no longer just whether a tool requires a license to export. […]
Firm Fixed Price at Award, Labor-Hour at Payment?
The problem is becoming familiar. A government agency awards a contract as firm-fixed-price. It evaluates bid proposals by looking hard at staffing plans, labor categories, and projected hours, sometimes even attaching a formula-laden spreadsheet to the solicitation to assist in the pricing of labor hours. But then, after award, it starts acting as though those […]
Identity One: When Corrective Action Doesn’t Fully Reset the Procurement
On April 13, 2026, the Government Accountability Office (“GAO”)’s decision in Identity One, LLC (B-424040.2; B-424040.3) denied Identity One, LLC (“Identity One”)’s challenge to the US Coast Guard’s implementation of corrective action after its prior protest. The procurement involved a request for proposals (“RFP”) for handheld biometric reader hardware, software, and maintenance services. Parroco Production […]
Agency Level Protests: Is Anyone Home?
I have filed three agency level protests this year and not heard back from any agency after filing. No acknowledgment, no courtesy call — nothing. I used to tell clients that if they want to preserve their relationship with the agency this is a better way to do it. It can also be done at […]
Executive Order Targets Claimed American Origin for Government Contractors
On March 13, 2026, to strengthen enforcement against false “Made in America” labeling, President Trump issued an Executive Order entitled, “ENSURING TRUTHFUL ADVERTISING OF PRODUCTS CLAIMING TO BE MADE IN AMERICA” (EO). The EO also provides new emphasis for government contractors, focusing on American country-of-origin claims as they relate to federal procurement. First, Section 2(d) […]
BIS Opens Door for Nvidia H200 & AMD MI325X Exports to China—With a 25% U.S. Cut. Opportunity or Trapdoor
In January 2026, the Bureau of Industry and Security (BIS) issued a final rule that changes how the U.S. government reviews export licenses for certain advanced AI semiconductors, such as Nvidia H200 and AMD MI325X equivalents, when they are headed to China or Macau. The previous policy was a presumption of denial, meaning most applications […]
Buy American Act (BAA) Calculation Fundamentals
We have had a lot of requests and questions lately regarding the BAA. This is unsurprising as the regulations can be very unclear at times and how they are applied. Although we have published several blogs on various topics concerning the BAA, TAA and Build America, Buy America laws and regulations, , in this blog […]