Weekly Update for Government Contractors and Commercial Businesses – September 2025 #4 | PilieroMazza PLLC
September 2025: Reducing the Negative Impacts of a Government Shutdown for Federal Contractors, PilieroMazza Client Alert, Jacqueline K. Unger, Nichole D. Atallah, Lauren Brier, Abigail “Abby” Finan
The federal government is set to run out of funding on September 30. While Congress is working on a continuing resolution to extend current funding levels and avert a government shutdown, it is currently being reported that the stopgap funding may be blocked unless the continuing resolution includes certain terms, such as extending expiring Affordable Care Act health insurance subsidies.
As we approach the possibility of another government shutdown, it’s crucial for government contractors to be prepared for the potential impacts on their operations. While shutdowns are not new, each one brings its own set of challenges and uncertainties. The current administration’s executive orders and actions have added an extra layer of uncertainty for government contractors. PilieroMazza provides key considerations and steps to take to ensure your business remains resilient during this period. Read more here.
Trump Scraps Meeting with Democrats, Raising Government Shutdown Risk, Reuters
U.S. President Donald Trump on Tuesday scrapped a meeting with top congressional Democratic leaders to discuss government funding, raising the risk of a partial government shutdown beginning next week. Read more here. Read more here.
New Bipartisan Bill Cracks Down on Contractor Price Gouging, Federal News Network
The legislation, dubbed the “Transparency in Contract Pricing Act of 2025,” requires contractors to notify the Defense Department if the cost of a product or service increases by more than 25% from the agreed contract bid or from what the government paid for the item in the previous calendar year. Read more here.
Upcoming Government Contract Presentations
TRAINING: Joint Venture and Mentor-Protege Bidding Strategies, October 2, 2025, Peter B. Ford, Meghan F. Leemon
PM WEBINAR: Managing the Financial Impact of Tariffs on Your Government Contract, October 7, 2025, Jacqueline K. Unger, Ryan Boonstra
SEMINAR: What the Future Holds for Federal Procurement, October 8, 2025, Isaias “Cy” Alba, IV
PM WEBINAR: Overcoming the Compliance Minefield of Cost-Reimbursement Contracts, Part 2: Mastering DCAA Audits in Cost-Plus-Fixed-Fee Contracts, October 14, 2025, Isaias “Cy” Alba, IV
PM WEBINAR: Avoiding Common Teaming and Subcontracting Pitfalls, October 16, 2025, Jon Williams
TRAINING: Legal Considerations: How Best to Structure Your Company as a Federal Contractor, October 21, 2025, Isaias “Cy” Alba, IV
TRAINING: Past Performance: How to Use Yours, Benefit from Others’, and Defend It from Attacks, October 28, 2025, Daniel Figuenick, III, Abigail “Abby” Finan
TRAINING: Limitations on Subcontracting: Key Updates and Tips for Compliance, November 4, 2025, Emily A. Reid, Abigail “Abby” Finan
TRAINING: Unlocking the Secrets of Debriefings, Government Evaluation of Proposals and Protests, November 6, 2025, Katherine B. Burrows, Eric Valle
PM WEBINAR: Maximizing Recovery: Tactics for Stop Work REAs and Termination Proposals, November 6, 2025, Legal Strategies & Capture Planning, November 7, 2025, Lauren Brier
PM WEBINAR: Overcoming the Compliance Minefield of Cost-Reimbursement Contracts, Part 3: Ready, Set, Comply! Build Indirect Rates That Stand Up to DCAA Scrutiny, November 12, 2025, Isaias “Cy” Alba, IV
CONFERENCE: Mission Critical: Compliance and Preparing Defense Manufacturers for SBA’s Latest Rules, November 17, 2025, Isaias “Cy” Alba, IV
General Services Administration (GSA) Multiple Award Schedule (MAS) Blog: Federal Acquisition Supply Chain Security Act (FASCSA) Order
On September 18, GSA issued a notice that a FASCSA order has been issued to remove and exclude products and services from Acronis AG. The full notice is available here.
HUD Joining GSA Centralized Acquisition Services Pilot, Federal News Network
The Department of Housing and Urban Development (HUD) is the third agency to move its contracting for common goods and services to the GSA. HUD joined the Office of Personnel Management and the Small Business Administration in using GSA’s Office of Centralized Acquisition Services for buying things like IT services, office management, or medical supplies under the category management initiative. Read more here.
Upcoming GSA Federal Supply Schedules Presentations
PM WEBINAR: Key Changes in GSA Schedule Contracting: What You Need to Know, October 2, 2025, Jon Williams
Federal Acquisition Regulation (FAR) Model Deviation Text for FAR Part 13
On September 18, the FAR Council released the model deviation text for FAR Part 13, Simplified Procedures for Non-Commercial Acquisitions. FAR Part 13 was updated to rename the FAR part from “Simplified Acquisition Procedures” to “Simplified Procedures for Non-Commercial Acquisitions.” As the name suggests, the FAR part was revised to apply only to non-commercial products and services below the simplified acquisition threshold. The General Services Administration’s (GSA) memorandum and class deviation fully incorporating the same into all GSA procurements are available here and will be effective November 3, 2025. Informal feedback is due November 3, 2025.
Department of Labor (DOL) News Release: DOL to Hold Online Seminars in September for Current, Prospective Federal Contractors on Prevailing Wage Requirements
On September 15, DOL announced that its Wage and Hour Division will offer the last of its fiscal year 2025 webinars on prevailing wage requirements for contractors, contracting agencies, unions, workers, and other stakeholders involved in federally funded construction and service contracts. The full notice is available here.
Your Guide to Pay and Benefits During a Shutdown, Government Executive
A lapse in appropriations looked likely after Senate Democrats rejected a plan to keep federal agencies open past September 30, while the House is not expected to return to Washington until next month. Read more here.
Bill to Nullify Trump’s Union Executive Orders Introduced by 48 Senators, Government Executive
All Senate Democrats and Sen. Lisa Murkowski, R-Alaska, have signed on as sponsors of the Protect America’s Workforce Act, while the measure is just two signatures away from guaranteed floor debate in the House. Read more here.
Upcoming Labor & Employment Presentations
PM WEBINAR: Multijurisdictional Employers, Part 4: Marijuana and Other Drug Testing in the Workplace, September 25, 2025, Sarah L. Nash, Sara N. Strosser
TRAINING: ABCs of the SCA: Critical Path Service Contract Act Training for Government Contractors, October 21-23, 2025, Nichole D. Atallah, Sarah L. Nash
TRAINING: Labor Rules & Regulations: Federal Market Compliance, October 22, 2025, Nichole D. Atallah
CONFERENCE: Unpacking and Seizing Opportunity in Changes to Labor and Employment, November 20, 2025, Nichole D. Atallah
Executive Order (EO): Further Extending the TikTok Enforcement Delay
On September 16, President Trump issued an EO extending the delay of EO 14166, Application of Protecting Americans from Foreign Adversary Controlled Applications Act to TikTok, until December 16, 2025. Read more here.
CISA Wants More International Involvement in Cyber Vulnerability Catalog, Official Says, NextGov/FCW
The Cybersecurity and Infrastructure Security Agency wants to involve more international partners in overwatching a long-standing cyber vulnerability cataloging project, which narrowly avoided vast defunding earlier this year, a top official said Wednesday. Read more here.
House CR Includes Short-Term CISA 2015 Extension, Federal News Network
House Republicans have included a short-term extension of the Cybersecurity Information Sharing Act of 2015 in a stopgap government funding bill, potentially giving lawmakers more time to work out updates to the decade-old CISA 2015 law. Read more here.
CMMC Audits Are Uncovering Hidden Export Control Risks, Federal News Network
The Defense Department’s Cybersecurity Maturity Model Certification is uncovering more than just cyber gaps. It’s also revealing export control violations that many contractors didn’t even know existed. Early assessments reveal ITAR and EAR violations that many contractors didn’t know they had, and the consequences can be serious. Read more here.
