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 blog. Here is a summary of what we covered in case you missed it. 

• Fixed Price Contracts are now the Default – but these are a new form of fixed price contract where the profit can be adjusted downward if you don’t meet certain milestones or labor hours.
• CMMC 2.0 Is No Longer Optional – the Cybersecurity Maturity Model Certification (CMMC) 2.0 final rule took effect in November 2025 and is now actively shaping which contractors can compete for Department of Defense work. Phase 1 — covering Level 1 and Level 2 requirements — runs through November 2026, during which self-assessments are permitted before award. However, third-party and government-led assessments will become mandatory over time, with full integration expected by 2028.
• GSA and AI – GSA’s draft contract clause, GSAR 552.239-7001, would impose significant obligations on any contractor providing AI solutions to the federal government — including full government ownership of all data inputs and outputs, a ban on using government data to train commercial models, and a 72-hour cybersecurity incident reporting requirement. GSA’s Multiple Award Schedule Refresh #31 (expected imminently) will introduce new AI requirements alongside an expanded Transactional Data Reporting pilot — changes every MAS holder needs to understand before the solicitation drops.
• Changes in Small Business Set-Asides – legislation before the House Committee on Small Business would codify the “Rule of Two” into federal law — a move that could significantly expand mandatory small business set-asides across the federal marketplace. On the flip side, a House and Senate bill would simultaneously eliminate many contracting preferences for minority- and women-owned businesses. 

On another note — this Memorial Day weekend, take a moment beyond the cookouts and long weekend to remember why we have this holiday — because of the men and women who wore this nation’s uniform and never came home. We are grateful for their courage, humbled by their sacrifice, and reminded that the work they did in service of this country carries meaning precisely because they gave everything to defend it.