Photo of M.Yuan ZhouPhoto of Kate GrowleyPhoto of Nkechi Kanu

This special edition covers the Pentagon’s recent suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements and initiation of a 60-day review by the CMMC Reform Task Force, and is hosted by Yuan Zhou, Kate Growley, and Nkechi Kanu. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief summary of significant government contracts legal and regulatory developments that no government contracts lawyer or executive should be without.

Continue Reading Special Edition of the Fastest 5 Minutes: Suspension of CMMC Phase II Requirements
Photo of Cherie Owen

The following is an installment in Crowell & Moring’s Bid Protest Sustain of the Month Series. In this series, Crowell’s Government Contracts Practice keeps you up to date with a summary of one of the most notable bid protest sustain decisions each month. Below, Crowell Consultant (and former GAO Bid Protest Hearing Officer) Cherie Owen discusses GAO’s decision in Veterans Management Services, Inc., which provides an important reminder that once an agency sets the rules for the procurement, it must play by them.

Continue Reading June 2026 Bid Protest Sustain of the Month: GAO Reminds Agencies that Once You’ve Set the Rules, You Have to Play by Them
Photo of Olivia LynchPhoto of Cherie Owen

As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights.

Continue Reading CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations
Photo of Kate GrowleyPhoto of Nkechi KanuPhoto of Jessica ChaoPhoto of Jacob HarrisonPhoto of Ajan JayantPhoto of Bryan DewanPhoto of Caitlyn Weeks

The Department of War (DoW) is immediately suspending Cybersecurity Maturity Model Certification (CMMC) Phase II requirements, which had been scheduled to take effect on November 10, 2026.

Continue Reading Department of War Immediately Suspends CMMC Phase II Requirements, Launches 60-Day Reform Review
Photo of Peter J. EyrePhoto of M.Yuan Zhou

This week’s episode covers new FAR Council guidance implementing the fixed-price contracting mandate under Executive Order 14402, a Federal Circuit decision on bid protest timeliness, an advance notice of proposed rulemaking about printed circuit boards, and a CAS Board final rule rescinding four Cost Accounting Standards, and is hosted by Peter Eyre and Yuan Zhou. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief summary of significant government contracts legal and regulatory developments that no government contracts lawyer or executive should be without.

Continue Reading Fastest 5 Minutes: Fixed-Price Contracting, Protests, CAS, Supply Chain
Photo of Cherie Owen

We recently discussed the Federal Circuit’s decision in Global K9 Protection Group, LLC v. United States and the importance of intervening in bid protests, especially when an awardee’s interests may diverge from the government’s. Now, a more recent Court of Federal Claims decision, West Pacific-CMCS JV v. United States, provides additional guidance regarding intervention by a contract awardee.

Continue Reading Recent Court Decisions Provide Intervention Insights
Photo of Christian CurranPhoto of Zachary SchroederPhoto of Bryan Dewan

Crowell & Moring’s “All Things Protest” podcast keeps you up to date on major trends in bid protest litigation, key developments in high-profile cases, and best practices in state and federal procurement. In this episode, Crowell’s Christian Curran, Zachary Schroeder, and Bryan Dewan discuss a recent Federal Circuit appeal on the Blue & Gold waiver rule, and a Court of Federal Claims protest about the “late is late” rule in the world of electronic proposal submissions.

Continue Reading All Things Protest: Blue & Gold and Late is Late
Photo of Christian CurranPhoto of Cherie OwenPhoto of Zachary Schroeder

In Utech, Inc. v. United States, No. 24-1586 (Fed. Cir. June 24, 2026), the U.S. Court of Appeals for the Federal Circuit clarified that in most cases, a pre-award protest must be filed before the proposal submission deadline to avoid the Blue & Gold waiver rule.  This decision, while nonprecedential, is in line with U.S. Government Accountability Office (GAO) precedent, which has long held that pre-award protests must be filed before the proposal submission deadline.

Continue Reading Federal Circuit Clarifies Application of Blue & Gold: Proposal Submission Deadline, Not Award, is the Operative Time for Filing
Photo of Erin Rankin

As part of its ongoing effort to conform the Cost Accounting Standards (“CAS”) to generally accepted accounting principles (“GAAP”), the CAS Board published a final rule rescinding CAS 408 (Accounting for costs of compensated personal absence) and CAS 411 (Accounting for acquisition costs of material).  The CAS Board also rescinded CAS 404 (Capitalization of tangible assets) and CAS 409 (Depreciation of tangible capital assets) but retained certain requirements of CAS 404 and 409, which will be located in new paragraphs of CAS 405 (Accounting for unallowable costs).  Specifically, the CAS Board retained the requirements currently located at CAS 404-50(d)(1), CAS 409-50(e)(5), CAS 409-50(j)(1), and CAS 409-50(j)(4), which the CAS Board explained are necessary to protect the Government’s interests.  Otherwise, the CAS Board determined that the requirements of CAS 404, 408, 409, and 411 overlapped with GAAP such that GAAP “may be applied reasonably as a substitute for CAS to support contract cost and pricing.”

Continue Reading CAS Board Publishes Final Rule Rescinding CAS 404, 408, 409, and 4117
Photo of Kate GrowleyPhoto of Jacob HarrisonPhoto of Ajan JayantPhoto of Bryan Dewan

On June 25, 2026, the Federal Risk & Authorization Management Program (FedRAMP) launched its Consolidated Rules for 2026, marking a significant turning point in how the U.S. government administers security authorizations of private sector cloud offerings. The Consolidated Rules apply to all variants of the FedRAMP ecosystem, including legacy “Rev5” authorization holders, as well as future certifications under the new 20x program. Importantly, the Rules are intended in part to transition Rev5 authorizations over to 20x, with the Rev5 authorization status expected to terminate by the end of 2028. 

Continue Reading Time for a Change: FedRAMP Fundamentally Revamps Program With Consolidated Rules for 2026