FAR Updates to Align with eSRS Decommissioning

GSA will decommission the Electronic Subcontracting Reporting System (eSRS.gov) on February 20, 2026, moving subcontracting reporting to SAM.gov, as part of the ongoing effort to modernize the suite of federal acquisition systems. To align with this change, the FAR Council has amended the FAR part 19 model deviation text. For more information, check out— To … [Read more…]

How the Latest Executive Order Reshapes Federal Grant Making and Oversight

What Federal Grant Recipients Need to Know About the New Executive Order What do all these changes mean and what should nonprofit and other grant recipients be prepared for? How all of these directives will be implemented is not currently known, and we would anticipate a fair number of differences among agencies, but we do … [Read more…]

Executive Order (EO) “Improving Oversight of Federal Grantmaking”

The second Trump administration has enacted numerous policy changes impacting federal grant recipients, including many nonprofit organizations. On August 7, the administration issued a new Executive Order (EO) that will more permanently affect both grantmaking and grant administration. “Improving Oversight of Federal Grantmaking” directs the implementation of several mechanisms designed to increase policy-level official oversight … [Read more…]

FAR Overhaul New Model Deviation Text for Parts 9, 33, 46, and 49

New FAR Council Model Deviation Text Now Available. The Federal Acquisition Regulatory Council has released new model deviation text as part of the ongoing Revolutionary FAR Overhaul (RFO) Initiative, in accordance with Executive Order 14275 and OMB Memorandum M-25-26. The following RFO updates were posted today, August 21, 2025: This release is part of a … [Read more…]

What’s the Deal if an Entity Ends Up on the 1260H List?

On January 2, 2025, the U.S. Department of Defense (DoD) refreshed its 1260H List, which names the entities classified as “Chinese military companies” (CMC) operating within the United States. This update is in line with section 1260H of the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2021. The revised list now features 76 … [Read more…]

FAR 52.249-6: Can a Prime Contractor Terminate Its Subcontractor Just Because Someone in the Government Says So?

Federal contracts famously include a clause permitting the government to terminate the agreement for the government’s own “convenience”—even if the contractor did not default on its performance obligations. Aware of this possibility, prime contractors typically add terms to their subcontracts permitting them to terminate on a similar basis. But a recent court case highlights the … [Read more…]