FAR 2.0 Update: Deviations and FAR Companion Guide

Posted on February 26, 2026 by Shane McCall

SmallGovCon readers may have read up on recent posts regarding the the Revolutionary FAR Overhaul, or simply RFO. For background, our earlier posts regarding various aspects of the RFO can be found here: Executive Order, Overview of FAR 2.0, FAR Part 6, FAR Part 19, FAR Part 12, FAR Part 15, FAR Part 33.

While the drumbeat of new FAR part revisions ended in October 2025, the RFO has not gone away. In fact, it’s kind of the opposite. The RFO revisions have now been adopted by many federal agencies as deviations, including the Department of Defense/War (DoW). Here is an update on the deviations and the FAR Companion guide.

SmallGovCon Week in Review: February 16-20, 2026

Posted on February 20, 2026 by Shane McCall

Happy Friday! After a stretch of surprisingly mild winter days, that brisk north wind rolled in yesterday and reminded us that it’s still February. Brrr! We were crossing our fingers that the groundhog’s prediction wouldn’t hold up this year and that spring would make an early appearance. Judging by today’s chill, though, it seems he may have been correct after all.

We hope your week has been a productive one and that you’re keeping cozy in your corner of the community. Take a moment to relax and enjoy the articles we’ve gathered for you below, including updates on the partial shutdown, a defense of the 8(a) Program, and DoD procurement overhauls. Have a great weekend.

Federal Court: Temp Workers Count As Employees Under SBA Rules

Posted on February 19, 2026 by Shane McCall

Small business size for federal procurement can be measured based on receipts or employee counts. Some small business procurements are set aside for small businesses as determined by the employee counts of those businesses, as opposed to the more common receipts based size-standard. SBA size rules, in turn, define what is an employee for those size standards that use employee counts, including whether temporary workers must be included in the employee count.

Employee counts were also utilized for PPP loan purposes, to determine what companies were eligible for PPP loans, with PPP loans only available to companies under certain headcounts. A recent federal district court decision turned on the definition of employee for PPP loan purposes. However, this case should be instructive for determining employee counts for all SBA purposes, including federal procurement, since the employee definitions for PPP loans and small business contracting are the same.

GAO: No Notice of New Opportunity Needed for Incumbents

Posted on February 19, 2026 by Gregory Weber

Often Incumbents on a contract feel that the agency owes them some notice on when a new procurement for the work they are performing is published. While this may happen in practice, it is yet another occurrence in Federal contracting that, while common, is not a requirement. GAO recently examined whether an incumbent in frequent contact with and in current performance with an agency should have been given direct notice that the work it had been performing was being re-solicited. Plainly put, GAO held that no special individualized notice was required to be sent to the incumbent, that there was to be a solicitation posted.

SmallGovCon Week in Review: February 9-13, 2026

Posted on February 13, 2026 by Shane McCall

Happy Friday the 13th! We hope your day is off to a lucky start and that everything is running smoothly. As a quick reminder, Valentine’s Day is tomorrow—so if it slipped your mind, there’s still time to grab some chocolate and flowers (and maybe avoid any Friday the 13th surprises!).

Valentine’s Day Fun Facts:

The Oldest Valentine: The oldest known valentine was a poem written in 1415 by Charles, Duke of Orleans, to his wife while he was imprisoned in the Tower of London.
Teachers Get the Most Love: Teachers receive the highest number of Valentine’s Day cards, followed by children, mothers, and wives.
Flower Power: Valentine’s Day and Mother’s Day are the busiest holidays for florists, with 189–250 million roses grown for the holiday.
Not Just for Humans: About 3% of pet owners give Valentine’s Day gifts to their pets.

We hope you get to spend time celebrating with your loved ones this weekend. Enjoy!

Now, on to this week in federal government contracting news. Key stories including the cancellation of CIO-SP4 and SBA moving forward with additional 8(a) terminations.

Why File: A Refresher on Challenging Solicitation Terms in a Pre-Award Protest

Posted on February 12, 2026 by Annie Birney

It is not uncommon for a disappointed bidder to consider filing a protest only after the agency has issued the award. While this is understandable, sometimes the basis for protesting stems from a misunderstanding of the solicitation’s terms, or that the terms felt unreasonably restrictive. However, unfortunately for the eager protester, it is by that point generally too late to challenge the terms of the solicitation.

In a previous blog, Why File: A GAO Pre-Award Protest, we provided an overview of different reasons to file a pre-award protest. As noted there, the most common basis for a pre-award protest is a challenge to the solicitation terms.

SmallGovCon Week in Review: February 2-6, 2026

Posted on February 6, 2026 by Shane McCall

Happy Friday! It’s time for another week in review. There was a lot happening across the federal government this week, as you can see from the long list of articles included below. We hope you have a chance to sit back, relax, and catch up on everything that unfolded. Have a wonderful weekend in your neck of the woods.

This week saw stories on ending the government shutdown, new spending bills, and cybersecurity.