On September 21, 2026, the Small Business Administration announced an extension of the comment period for two previously proposed rules that, as currently constructed, would significantly expand the pool of entities eligible to qualify for small business set-aside procurements. The extension is slated to be formally published on September 24, 2026. While the comment period
Zachary Schroeder
Zachary Schroeder is a counsel in Crowell & Moring’s Washington, D.C. office, where he practices in the Government Contracts Group.
Zach represents contractors in both litigation and counseling matters. His practice focuses on representing contractors in bid protests before the Government Accountability Office (GAO), the U.S. Court of Federal Claims, and the Federal Aviation Administration’s Office of Dispute Resolution for Acquisition. His practice also includes federal regulatory and ethics compliance, as well as various aspects of state and local procurement law, including representing contractors in size protests and affiliation matters. In the transactional context, Zach has performed government contracts diligence for government contractors in a range of industries.
While in law school, Zach served as a judicial intern for Judge Mary Ellen Coster Williams at the U.S. Court of Federal Claims. He also served as the chair of the 2017 Government Contracts Moot Court Competition and as an editorial staff member of the American Intellectual Property Law Association (AIPLA) Quarterly Journal.
SBA Proposal to Overhaul Size Standards Would Transform Federal Government Contracting
On August 20, 2026, the Small Business Administration (SBA) proposed to materially amend the way it establishes size standards for purposes of federal procurement.
Continue Reading SBA Proposal to Overhaul Size Standards Would Transform Federal Government ContractingAll Things Protest: Blue & Gold and Late is Late
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 LateFederal Circuit Clarifies Application of Blue & Gold: Proposal Submission Deadline, Not Award, is the Operative Time for Filing
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 FilingSBA OHA Confirms That the Submission Date for a Proposal with Pricing Controls Size Determination
On April 8, 2026, the Small Business Administration’s (SBA) Office of Hearings and Appeals (OHA) denied an appeal arguing that a concern’s early submission of its proposal with pricing was an attempt to “end-run the regulations” for when size is determined. In Size Appeal of DecisionPoint Corporation, SBA No. SIZ-6379, OHA confirmed that a company’s size is determined on the date it submits its initial offer which includes price, even if the proposal is submitted in advance of the proposal submission deadline and the offeror becomes large before the provided deadline.
Continue Reading SBA OHA Confirms That the Submission Date for a Proposal with Pricing Controls Size DeterminationDon’t Get Left in the Doghouse: The Federal Circuit’s Global K9 Case and the Duty to Intervene
On May 14, 2026, the U.S. Court of Appeals for the Federal Circuit issued a stark warning to government contractors: when a bid protest is filed involving your contract, failing to timely intervene can cost you the ability to defend your award. In Global K9 Protection Group, LLC v. United States, the Federal Circuit upheld the denial of K2 Solutions, Inc.’s motion to intervene, finding that K2 had waited too long to act despite having sufficient reason to do so.
Continue Reading Don’t Get Left in the Doghouse: The Federal Circuit’s Global K9 Case and the Duty to InterveneAll Things Protest: Final Proposal Revisions and Federal Circuit Opinions
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 GAO sustain about final proposal revisions, along with two notable Federal Circuit opinions from May 2026 covering bid protest intervention and the discretion afforded to agencies in evaluating proposals.
Continue Reading All Things Protest: Final Proposal Revisions and Federal Circuit OpinionsAll Things Protest: Challenging Agency Evaluations of Proposals
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 challenges contractors face when protesting agency evaluations of proposals, along with…
Fastest 5 Minutes: Audits of Federal Small Business Program Awards
This episode addresses efforts by various federal government agencies to audit and investigate purported ‘waste, fraud, and abuse’ in small business set-aside awards, and is hosted by Yuan Zhou, Olivia Lynch and Zach Schroeder. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief summary of significant government contracts legal and regulatory…
All Things Protest: Corrective Action at the Court of Federal Claims
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 cover two recent protests at the Court of Federal Claims— Advantaged Solutions…