J. Ryan Frazee

The government contracting landscape is being reshaped in ways that few could have anticipated. The formation of the Department of Government Efficiency, combined with sweeping executive orders, mass agency personnel reductions and widespread contract terminations have introduced significant uncertainty into a previously stable federal market environment.

WHAT: The March 14 funding deadline is fast approaching, and it is increasingly likely that the federal government may shut down. Although the House narrowly passed a funding bill this week, the Senate has signaled that it may not advance. In light of the late hour, a shutdown is increasingly possible if a resolution is not reached.

WHAT: The odds of a federal government shutdown occurring have increased substantially after a gridlocked Congress, spurred by the incoming Administration, has been unable to reach an agreement on a continuing resolution, and the White House has now instructed agencies to prepare for a shutdown. Now, there is precious little time before government funding runs out in just hours – at midnight on Saturday, December 21. To help contractors navigate this impending storm, we are reprising an alert we issued in September 2023, the last time a shutdown loomed on the horizon.

On December 18, 2024, the Senate passed the National Defense Authorization Act for Fiscal Year 2025 (NDAA), which the House of Representatives passed the previous week. President Biden is expected to sign the bill into law soon. The NDAA contains numerous provisions that impact government contractors, either directly or indirectly. Below are highlights of the important government contracts-related provisions of the NDAA. Some of these provisions will take effect immediately upon enactment of the NDAA, but others will require implementing regulations before contractors see any changes in acquisition policies and procedures.

On June 28, 2024, the U.S. Supreme Court sent shockwaves across the administrative law landscape when it handed down Loper Bright Enterprises v. Raimondo, overruling the 40-year-old Chevron doctrine and its two-step framework that required courts to defer to agency interpretations of ambiguous statutes.