Government Contracting – Key Developments in April 2025

OASIS+ Small Business and Socioeconomic Set-Aside Awards Announced; WOSB Awards Delayed Due to Protest

In April 2025, the U.S. General Services Administration (GSA) made major announcements regarding the OASIS+ multiple award contracts. Apparent awardees for Small Business Set-Asides and Socioeconomic Set-Asides (WOSB, SDVOSB, HUBZone, and 8(a)) were named, marking a significant milestone for the program. However, the awards for Women-Owned Small Business (WOSB) Set-Aside contracts have been delayed following a formal protest filed with the Government Accountability Office (GAO).

Key Details:

April 3, 2025:

GSA announced apparent awardees for the OASIS+ Small Business Set-Aside: 

• 190 Small Businesses Selected across seven domains:
  • Management & Advisory Services: 123
  • Technical & Engineering Services: 103
  • Intelligence Services: 20
  • Research & Development Services: 21
  • Logistics Services: 13
  • Facilities Services: 22
  • Environmental Services: 10
• Notifications sent via email to successful offerors.
• Full list of awardees posted on SAM.gov

April 4, 2025:

GSA announced apparent awardees for the OASIS+ Socioeconomic Set-Asides:

• WOSB: 130
• SDVOSB: 112
• HUBZone: 130
• 8(a): Rolling awards by domain
• Notifications sent to offerors and available in SAM.go

April 16, 2025: (Original Plan)

• Awards and Notices to Proceed (NTPs) for Small Business and Socioeconomic Set-Aside contracts were scheduled to begin
• GSA’s eBuy platform was scheduled to open for ordering after contractor registration

April 16, 2025: (Update)

• WOSB Awards Delayed:
  • A protest was filed under 31 U.S.C. § 3553, triggering an automatic stay of the WOSB award process
  • GSA has postponed the WOSB awards and NTPs until the GAO resolves the protest
  • No revised award timeline has been announced yet

For most Small Business Set-Aside awardees (outside of WOSB), contract awards and onboarding processes are progressing as planned, marking a major opportunity to access federal procurement under the OASIS+ vehicle.
However, Women-Owned Small Businesses face uncertainty due to the protest-induced delay. Contractors affected by the WOSB delay should stay in close communication with GSA and monitor SAM.gov for protest resolution updates. All awardees should also ensure SAM.gov registrations are accurate and active to avoid delays in receiving formal awards and task order opportunities once ordering begins.
Additionally, firms that have not received an award notice yet are reminded that rolling awards are ongoing, and evaluations continue for pending proposals.

White House Announces Sweeping Federal Procurement Overhaul: Key Executive Orders Explained

On April 15, 2025, the White House introduced a comprehensive reform of the federal procurement system through two distinct, yet interrelated Executive Orders. This reform aims to enhance efficiency, reduce complexity, and ensure better stewardship of taxpayer dollars.

The announcements collectively reflect the administration’s intent to modernize procurement, emphasizing market-driven solutions, regulatory simplification, and heightened accountability. Contractors and federal agencies alike should closely review these changes to fully understand their operational implications.

Overview of the Procurement Overhaul Initiative

The administration’s procurement reform strategy revolves around two major executive actions:

1. Restoring Common Sense to Federal Procurement
2. Enforcing Cost-Effective Commercial Solutions in Federal Contracts

Both initiatives share a common goal: streamlining procurement to optimize government spending efficiency and leverage existing commercial innovations more effectively. 

Analysis of the Two Executive Orders

Executive Order 1: Restoring Common Sense to Federal Procurement

This Executive Order directly targets the complexity of the Federal Acquisition Regulation (FAR), which historically has been viewed as cumbersome, difficult to interpret, and a barrier to efficiency. 

Key components include:

• 180-Day FAR Regulatory Review: The FAR Council is tasked with conducting a comprehensive review of existing regulations, recommending removal or revision of outdated, redundant, or overly burdensome rules
• Clear Legal Basis: Any regulation without explicit statutory justification must be reconsidered, revised, or eliminated. This may significantly simplify the FAR structure, making it more accessible and practical
• Emphasis on Clarity and Practicality: New or revised FAR clauses must be written plainly and clearly to ensure accessibility for both agencies and contractors

Insights and Implications:

• This reform is likely to positively impact federal procurement speed, allowing for quicker solicitation cycles and faster award timelines
• Contractors can expect reduced administrative costs associated with compliance
• Agencies may initially face implementation challenges as they adapt to revised rules and processes but ultimately should experience increased operational flexibility

Executive Order 2: Enforcing Cost-Effective Commercial Solutions

This Executive Order underscores the administration’s preference for commercial solutions over custom-developed products and services. It mandates commercial procurement as the default, with few exceptions.

Key provisions include:

• Mandatory Commercial Solutions: Federal agencies must procure commercial-off-the-shelf (COTS) products and services whenever feasible, unless an explicit waiver is justified and approved by senior leadership
• Waiver Approval Process: For non-commercial acquisitions, agencies must demonstrate clearly why commercial solutions are inadequate, increasing transparency and accountability
• Contract Reviews: Agencies are instructed to review ongoing contracts within a 60-day period, ensuring alignment with commercial solution requirements, reinforcing proactive management of existing contracts

Insights and Implications:

• Vendors with readily available commercial solutions may experience increased contracting opportunities
• Companies relying heavily on tailored government-specific solutions should anticipate potential adjustments and prepare for rigorous justification processes
• The order encourages a competitive marketplace that could lead to cost savings and foster innovation by leveraging established commercial capabilities

Considerations for Government Contractors

As these changes take effect, federal contractors should proactively assess their current contracting approaches and business models:

• Commercial Readiness: Contractors should ensure their commercial product and service offerings are clearly defined, well-documented, and competitively priced
• Compliance and Adaptation: Contractors must remain vigilant regarding ongoing FAR modifications to swiftly adjust internal compliance processes
• Market Positioning: Businesses may need to reevaluate market strategies and explore potential partnerships or product modifications to align with commercial solution mandates

GSA Launches ‘OneGov’ Strategy to Streamline Federal Procurement

On April 29, 2025, the General Services Administration (GSA) introduced the ‘OneGov’ Strategy, a comprehensive initiative aimed at overhauling the federal government’s technology acquisition process. This multi-phase plan seeks to simplify procurement by establishing standardized terms and pricing, fostering direct relationships between federal agencies and original equipment manufacturers (OEMs), and reducing reliance on resellers. 

Key Details:

• Standardization and Direct Procurement: The initial phase of the OneGov Strategy focuses on providing agencies with access to IT tools under standardized terms and pricing. By encouraging direct procurement from OEMs, the GSA aims to streamline the acquisition process and enhance cost-effectiveness
• Expansion to Other Categories: Future phases of the strategy are expected to extend these procurement principles to additional categories, including hardware machinery and cybersecurity services. The GSA plans to collaborate with agency and industry stakeholders to guide the implementation of these subsequent phases
• Recent Agreements: In alignment with the OneGov Strategy, the GSA recently secured a government-wide agreement with Google, offering federal agencies a 71% discount on the Workspace software suite. This deal exemplifies the strategy’s emphasis on leveraging the federal government’s collective purchasing power to achieve significant cost savings

Implications for Government Contractors and Small Businesses:

• Shift in Procurement Dynamics: The move towards direct procurement from OEMs may alter traditional procurement channels, potentially impacting resellers and intermediaries. Contractors should assess their roles in the supply chain and explore opportunities to adapt to the evolving procurement landscape
• Opportunities for OEMs: OEMs may find increased opportunities to engage directly with federal agencies, necessitating a focus on compliance with federal procurement standards and readiness to meet agency-specific requirements
• Emphasis on Efficiency and Cost Savings: The OneGov Strategy underscores the federal government’s commitment to efficient spending and streamlined procurement processes. Contractors and small businesses should align their offerings with these priorities to remain competitive in the federal marketplace

The GSA’s OneGov Strategy represents a significant step towards modernizing federal procurement, emphasizing standardization, direct engagement with OEMs, and cost savings. As the strategy unfolds, contractors and small businesses should stay informed about its developments and consider strategic adjustments to align with the new procurement framework.

DoD Hiring Still Mostly Frozen, With Key Exemptions as of April 2025

As of April 2025, the Department of Defense (DoD) continues to enforce a near-total civilian hiring freeze, initiated under the Trump administration’s directive to shrink the federal workforce. However, specific essential roles have been exempted to maintain mission readiness and critical services. The freeze remains a major policy shift affecting the DoD’s hiring practices.

Key Details:

• Workforce Reduction Goal: DoD aims to cut up to 8% of the civilian workforce, reducing about 6,000 positions per month
• Exempted Positions:
  • Child and youth programs (including DoD schools and childcare centers)
  • Civilians at medical treatment facilities
  • Staff at the Military Entrance Processing Command
  • Fire and safety services personnel
  • Workers at depots, shipyards, and arsenals
• Exemption Request Process:
  • Departments must submit exemption requests weekly (by Tuesday COB) to the Deputy Assistant Secretary for Civilian Personnel Policy
  • Impact on Civilian Workforce:
  • Broader staffing shortages expected
  • Deferred Resignation Program and early retirements encouraged
  • After the freeze lifts, only 1 hire per 4 departures will be permitted

For contractors and small businesses supporting the DoD, this freeze could translate to delayed new contract staffing and more competition for fewer available civilian roles. However, exempted functions such as healthcare, child services, and logistics support will still present stable or growing contracting opportunities. Contractors engaged in these critical areas may even find increased demand for outsourced solutions as DoD struggles to staff internally. Moreover, firms specializing in surge support, temporary staffing, or installation services could see expanded needs as civilian gaps widen.

DoD Acquisition Nominee Commits to Reviewing CMMC and Multiuse SCIFs

Michael Duffey, President Donald Trump’s nominee for Under Secretary of Defense for Acquisition and Sustainment, has pledged to review the Cybersecurity Maturity Model Certification (CMMC) program and the use of multiuse Sensitive Compartmented Information Facilities (SCIFs). This commitment comes as the Department of Defense (DoD) works to finalize CMMC requirements aimed at enhancing cybersecurity across the defense industrial base.

Key Details

• CMMC Program Review: Duffey expressed the importance of ensuring that defense contractors meet contractual cybersecurity requirements. He stated that, if confirmed, he would evaluate the current CMMC requirements and consider improvements to make compliance more affordable and aligned with current best practices
• Assessment Organizations: He also indicated plans to review the role of third-party assessment organizations (3PAOs) and the Cyber Accreditation Body responsible for accrediting these entities, which are crucial for assessing contractors’ network security practices
• Implementation Timeline: The DoD aims to implement CMMC requirements starting this year but faces challenges due to a deregulatory push requiring the repeal of existing regulations for each new one introduced
• Small Business Considerations: Duffey acknowledged the varying cybersecurity capabilities among defense contractors and emphasized the need to balance security requirements with the regulatory burdens on small and medium-sized businesses

Duffey’s commitment to reviewing the CMMC program signals a potential shift towards more flexible and cost-effective cybersecurity requirements for defense contractors, particularly small businesses. A review of 3PAOs and the accreditation process may lead to more streamlined assessments, reducing compliance burdens. Contractors should stay informed about potential changes to CMMC requirements and be prepared to adapt their cybersecurity practices accordingly.

Army Commits $1B to ‘Transformation in Contact 2.0’ for Rapid Modernization

The U.S. Army is significantly expanding its “Transformation in Contact“ (TiC) initiative, allocating $1 billion through fiscal year 2027 to accelerate modernization efforts. This marks a substantial increase from the $15 million invested in the program’s initial phase in 2024.

Key Details

• Increased Investment: The Army plans to invest $1 billion in TiC between now and the end of fiscal year 2027, a significant jump from the $15 million spent on the first three TiC brigades in 2024
• Expanded Testing: The next iteration will test more drones, vehicles, and electronic warfare systems. Specifically, the Army aims to test 1,100 unmanned aerial systems (UAS), 2,000 mobility systems, 1,200 counter-UAS systems, and 250 electronic warfare system
• Broader Unit Participation: The program will expand beyond the initial three infantry brigade combat teams to include a Stryker brigade, two armored combat brigades, and, by fall, protection and sustainment unit
• Acquisition Reform: The Army is attempting to break out of its traditional acquisition cycle by allowing defense contractors to bring systems directly to Army units in the field for live feedback and immediate changes

The expansion of the TiC initiative presents significant opportunities for defense contractors and small businesses. By allowing direct collaboration with Army units in the field, contractors can receive immediate feedback and make rapid adjustments to their systems. This approach reduces the time and resources typically required in the traditional acquisition process. Small businesses, in particular, can benefit from the streamlined process, as it lowers barriers to entry and accelerates the deployment of innovative solutions. Additionally, the increased investment in TiC indicates a growing demand for advanced technologies, creating a favorable environment for contractors specializing in unmanned systems, mobility solutions, and electronic warfare capabilities.

OHA Mandates SBA to Consider Operating Agreements in Joint Venture Size Determinations

On February 12, 2025, the Small Business Administration’s (SBA) Office of Hearings and Appeals (OHA) issued a pivotal decision in the case of DecisionPoint-Agile Defense JV, LLC, SIZ-6336. This ruling emphasizes that the SBA must consider a joint venture’s operating agreement (OA) during size determinations, even if the OA isn’t explicitly incorporated into the joint venture agreement (JVA). This decision underscores the significance of comprehensive documentation in joint ventures, especially for those participating in mentor-protégé programs and pursuing small business set-aside contracts.

Key Details

• Case Background: The SBA’s Area Office previously determined that the joint venture (JV) was affiliated with its mentor, rendering it ineligible for small business status. This conclusion was based solely on the JVA, disregarding the OA
• OHA’s Ruling: OHA found that the OA contained critical provisions demonstrating the JV’s compliance with SBA regulations. The decision clarified that the OA, as a fundamental governing document of a limited liability company, is inherently relevant in size determinations, regardless of its incorporation into the JVA
• Implications for SBA Regulations: While SBA regulations stipulate that mandatory provisions must be in the JVA, OHA’s decision allows for a holistic review of both the JVA and OA to assess compliance

This ruling has significant implications for small businesses and government contractors:

• Comprehensive Documentation: Both the JVA and OA should be meticulously drafted to reflect compliance with SBA regulations
• Legal Review: Engaging experienced legal counsel to review all joint venture documents can prevent adverse size determinations
• Strategic Planning: Understanding that OAs are now a critical component in size determinations allows businesses to better structure their joint ventures to maintain small business eligibility

White House Unveils New AI Policies to Streamline Federal Adoption and Procurement

On April 7, 2025, the White House announced significant policy updates aimed at accelerating the adoption and procurement of artificial intelligence (AI) technologies across federal agencies. These changes, detailed in Office of Management and Budget (OMB) Memoranda M-25-21 and M-25-22, are designed to remove bureaucratic barriers, promote innovation, and ensure responsible AI use within the federal government.

Key Policy Highlights

• Empowering Chief AI Officers (CAIOs): Agencies are directed to appoint or reaffirm CAIOs who will serve as advocates for AI innovation, responsible for promoting AI adoption and advising on investments
• AI Maturity Assessments: Agencies must conduct assessments to evaluate their current AI capabilities and identify areas for growth
• Streamlined Procurement Processes: The new policies aim to simplify AI acquisition by eliminating redundant reporting requirements and encouraging the use of American-made AI solutions
• Focus on High-Impact AI: A single category for “high-impact AI” has been introduced to ensure heightened due diligence for AI applications that significantly affect the public

These policy changes present new opportunities for contractors and small businesses specializing in AI technologies:

• Increased Opportunities: Simplified procurement processes may lower barriers to entry, allowing more businesses to compete for federal AI contract
• Emphasis on American-Made Solutions: A focus on domestic AI products could benefit U.S.-based companies offering innovative AI service
• Need for Compliance: Contractors must ensure their AI solutions align with the new policies, particularly concerning high-impact AI applications

DoD Issues Reporting Instructions for Contract Terminations and Cancellations

On April 3, 2025, the Department of Defense (DoD) released a memorandum titled “Reporting Instructions to Comply with Presidential Action Memorandum ‘Radical Transparency About Wasteful Spending’ dated February 18, 2025.” This directive provides comprehensive guidance for DoD components on reporting termination and cancellation actions in alignment with the administration’s efficiency initiatives. 

Key Reporting Requirements

• Mandatory Reporting: All DoD components are required to report contract terminations and cancellations resulting from the efficiency initiatives
• Reporting Platforms:
  • Federal Procurement Data System (FPDS): Used for detailed contract action reports
  • System for Award Management (SAM): Utilized for posting notices of terminations and cancellations
• Transparency Measures: While FPDS entries have a 90-day public release delay, notices posted in SAM are immediately available to the public, ensuring prompt transparency

The DoD’s emphasis on transparency and efficiency may lead to increased scrutiny of contracts, particularly those deemed non-essential. Contractors should:

• Review Contracts: Assess current contracts for alignment with the administration’s efficiency goals
• Stay Informed: Regularly monitor FPDS and SAM for updates on contract statuses
• Engage Proactively: Communicate with contracting officers to understand potential impacts and adjust strategies accordingly

Defense Secretary Hegseth Announces Additional $5.1 Billion in Pentagon Spending Cuts

On April 10, 2025, Defense Secretary Pete Hegseth announced an additional $5.1 billion in Department of Defense (DoD) spending cuts, targeting what he described as “wasteful” contracts. This move is part of the ongoing efforts by the Department of Government Efficiency (DOGE) to streamline defense expenditures.

Breakdown of the $5.1 Billion Cuts

The memorandum signed by Secretary Hegseth outlines several areas where contracts will be terminated or reduced:

• Consulting Services: Approximately $1.8 billion in consulting contracts awarded by the Defense Health Agency to private sector firms will be cut
• Enterprise Cloud IT Services: A $1.4 billion contract awarded to a software reseller for enterprise cloud IT services is slated for cancellation
• Navy Business Process Consulting: A $500 million contract for business process consulting within the Navy will be eliminated
• IT Help Desk Services: A $500 million contract awarded to the Defense Advanced Research Projects Agency (DARPA) for IT help desk services, deemed duplicative of existing services provided by the Defense Information Systems Agency, will be terminated
• Nonessential Activities: Eleven contracts related to diversity, equity, and inclusion (DEI), climate change initiatives, and COVID-19 response activities across the DoD will be cut
• Academic Funding: Over $500 million in funding to two universities, cited for tolerating antisemitism and supporting divisive DEI programs, will be paused. This is in addition to the $70 million already cut by three other colleges in previous weeks

These cuts are in addition to the $580 million in reductions announced on March 20, 2025, bringing the total identified savings to nearly $6 billion within the first six weeks of DOGE’s operations.

These measures are part of a larger initiative to realign the DoD’s budget with current strategic priorities. Earlier in February 2025, Secretary Hegseth directed an 8% budget reduction across Pentagon agencies, amounting to approximately $50 billion in cuts. The focus of these reductions includes reallocating funds toward border security and modernizing nuclear forces, while exempting areas such as Virginia-class submarines and cybersecurity.

CISA Extends MITRE’s CVE Program Contract, Averting Potential Cybersecurity Disruption

On April 16, 2025, the Cybersecurity and Infrastructure Security Agency (CISA) extended its critical contract with MITRE Corporation to manage the Common Vulnerabilities and Exposures (CVE) Program, mere hours before the agreement was set to expire. The CVE Program is essential in providing standardized identifiers for known cybersecurity vulnerabilities, helping both government and industry effectively track, communicate, and manage cyber threats. The last-minute contract extension follows uncertainty over the program’s future funding, prompting discussions about its long-term sustainability.

Key Details:

• 11-Month Contract Extension: CISA renewed the CVE Program contract with MITRE, extending operations for another 11 months
• Funding Uncertainty: Prior to this renewal, MITRE had announced that funding would lapse on April 16, risking significant disruption to vulnerability tracking and cybersecurity coordination
• Industry Concerns: The cybersecurity community voiced strong concerns regarding potential operational interruptions, emphasizing the CVE program’s critical role in national cybersecurity
• Proposed Long-term Solutions: In response to the funding uncertainty, CVE Board members proposed creating an independent nonprofit—the CVE Foundation—to sustainably manage the program beyond government contracts
• Continued Governance Discussions: Although immediate disruption has been avoided, ongoing conversations about alternative, community-based management models continue

The CVE Program’s extension ensures uninterrupted cybersecurity communication and vulnerability tracking for government contractors, agencies, and small businesses reliant on timely security advisories. Had the contract lapsed, contractors could have faced confusion or delayed responses to emerging cyber threats, risking compliance, security breaches, and operational disruptions. This renewal provides immediate relief but also signals the need for contractors to stay informed about potential changes to the program’s governance, ensuring preparedness for any future transitions in vulnerability reporting processes.