Government Contracting – Key Developments in March 2025

MAPS RFP Delayed Amid Executive Order Review on Procurement Consolidation

Key Details:

• Delay Announced: The Final Draft MAPS RFP and the virtual Pre-Solicitation Conference (previously scheduled for April 2, 2025) are postponed until further notice.
• Triggering Policy: The delay is a direct result of an Executive Order requiring federal agencies to review their procurement vehicles and consolidate efforts where appropriate.
• Army’s Statement: The Army acknowledged the importance of industry input and confirmed it is actively reviewing MAPS in light of the new directive.
• Communication Commitment: Further updates will be issued as soon as the review concludes and revised timelines are determined.

GSA to Oversee Federal Purchasing: A Step Toward Efficiency or a Challenge for Agencies and Contractors?

In a major policy development, the General Services Administration (GSA) has been designated to oversee and coordinate all federal purchasing—a significant consolidation of procurement authority intended to streamline operations, reduce duplication, and increase efficiency across federal agencies. While the move could improve government buying power and simplify processes, it also raises concerns among contractors and agencies about centralized control, flexibility, and implementation hurdles.

Key Details:

1. Policy Shift:

•  GSA has been tasked with centralized oversight of federal procurement activities, effectively becoming the government’s lead buyer.

2. Goals of the Consolidation:

• Reduce duplication and inefficiencies in federal purchasing.
• Establish unified procurement standards and shared services.
• Leverage GSA’s expertise to negotiate better pricing and terms.

3. Implementation Concerns:

• Agencies may lose flexibility in tailoring procurement to mission-specific needs.
• Questions remain about how GSA will coordinate with agency procurement officers.
• Possible delays in procurement cycles as new coordination processes roll out.

4. Legal and Regulatory Implications:

• Contractors may face new compliance standards or contract terms that differ from previous agency-specific norms.
• Agencies must align their procurement strategies with GSA’s guidance and may require retraining or systems integration.

This centralization could streamline the path to federal contracts, particularly for vendors already on GSA Schedules or experienced with GSA procurement practices. Small businesses that rely on direct relationships with specific agencies, however, may face additional layers of oversight and less individualized procurement paths. Contractors should closely monitor how GSA’s expanded authority is implemented, prepare for possible changes in acquisition strategies, and ensure they are positioned to align with standardized contract vehicles and pricing models favored by GSA. While this reform aims to improve efficiency, it may introduce short-term confusion and longer procurement lead times during the transition.

GSA Issues Amendment A0012 to Alliant 3 RFP – Proposal Deadline Extended and New Experience Types Allowed

On March 12, 2025, the General Services Administration (GSA) issued Amendment A0012 to the Alliant 3 Government-Wide Acquisition Contract (GWAC) RFP (Solicitation No. 47QTCB24R0009). This update extends the proposal deadline and provides important changes to relevant experience criteria, including the acceptance of Other Transaction Agreements (OTAs) and Basic Ordering Agreement (BOA) task orders as qualifying experience. It also offers clarification on the required systems, certifications, and clearances.

Key Details:

• New Proposal Due Date: Extended from March 31, 2025 to April 11, 2025
• Expanded Experience Types: Now includes OTAs and BOA task orders as valid relevant experience under Section L.5.2.1
• Clarifications Added: Detailed guidance on timeliness of systems, certifications, and clearances in Sections L.5.4.6 to L.5.4.9
• Updated Documents: Full amendment details are available in Version 12 of the Conformed RFP and SF30 Amendment 0012 on SAM.gov

This amendment offers greater flexibility for offerors by expanding the types of relevant experience accepted, which is especially beneficial for non-traditional contractors or those working under innovative contracting vehicles like OTAs or BOAs. The extended deadline gives small businesses and large firms more time to finalize proposals while ensuring compliance with updated submission requirements. Contractors should immediately review the revised sections of the RFP to adjust their proposal strategies and verify that their credentials, systems, and security clearances meet the clarified standards.

NASA Begins Planning ELVIS 4 Recompete, Seeks Small Business Input

NASA has officially begun market research for its upcoming Evolving Launch Vehicle Integrated Support 4 (ELVIS 4) contract, which will succeed the current ELVIS 3 contract held by A.I. Solutions Inc. The recompete focuses on engineering and technical support services for NASA’s Launch Services Program and associated liftoff sites, with a planned start date no earlier than October 2026.

Key Details:

• Current Contract: ELVIS 3 was awarded in 2016 to A.I. Solutions Inc., with an estimated $338.5 million in task order obligations to date.
• Planned Successor: ELVIS 4 will provide continued support at major NASA liftoff locations:
  • Kennedy Space Center (FL)
  • Cape Canaveral Space Force Station (FL)
  • Vandenberg Space Force Base (CA)
• High-Level Categories of Work:
  • Launch services safety, reliability, and quality engineering
  • Launch site support engineering
  • Launch vehicle insight
  • Communications and telemetry
  • Information Technology (IT)
• Small Business Focus:
  • NASA is actively seeking input from small businesses, HBCUs, and minority-serving institutions.
  • The agency will use this feedback to assess whether ELVIS 4 should be set aside for small business or other socioeconomic categories (8(a), WOSB, SDVOSB, HUBZone, etc.).
• RFI Response Deadline: March 18, 2025

The ELVIS 4 opportunity signals a major federal engineering and IT contract that could open the door to greater small business participation in NASA’s launch infrastructure. Firms specializing in aerospace engineering, systems support, telemetry, or IT services should closely review the draft scope and submit capability statements or feedback by the RFI deadline. If NASA determines sufficient small business interest, the contract may be structured as a set-aside, dramatically increasing access for emerging contractors and historically underrepresented institutions. Early engagement could also help shape the final solicitation in a way that supports diversity and innovation in the federal space sector.

SPUR Act Promotes Small Business Participation in Federal Contracting

The Small Business Procurement and Utilization Reform (SPUR) Act (H.R.818) has been reintroduced in the 119th Congress to strengthen the role of small businesses in federal procurement. The bill seeks to increase oversight and accountability in how federal agencies meet small business contracting goals, while also empowering the Offices of Small and Disadvantaged Business Utilization (OSDBUs) to advocate more effectively for small firms.

Key Details:

• OSDBU Empowerment:
  • Grants OSDBU Directors direct access to the agency head and a defined role in acquisition planning.
  • Prevents agencies from excluding OSDBUs from key procurement decisions.
• Accountability Measures:
  • Requires each federal agency to track and report compliance with small business participation goals.
  • Mandates a public-facing scorecard for transparency.
• Corrective Actions for Non-Compliance:
  • Agencies consistently failing to meet small business goals may be required to implement corrective action plans.
  • Could result in performance evaluations tied to small business utilization.
• Codifies Best Practices:
  • Encourages early and meaningful engagement with small businesses during acquisition planning.
  • Promotes regular training for contracting officers on small business utilization strategies.
• Legislative Intent:
  • To reverse trends of declining small business participation in federal contracts.
  • Reinforces bipartisan support for small business access to federal markets.
• Status (as of March 2025):
  • The bill is in committee review after being introduced in the House.
  • Supporters are pushing for quick markup and passage.

If passed, the SPUR Act would create stronger institutional support for small businesses across federal agencies. By empowering OSDBUs and holding agencies accountable for small business goals, the legislation aims to reduce barriers to entry and promote more equitable access to federal contracts. Small businesses could benefit from earlier engagement in acquisition planning, improved visibility into agency performance, and more responsive advocacy during the procurement process. The bill signals a potential shift toward systemic reform in how small business participation is enforced and prioritized.

Final Protests for NASA SEWP VI RFP Withdrawn

In a major development for federal IT contractors, NASA SEWP VI procurement can now proceed without further delays, as all remaining bid protests have been officially withdrawn as of March 13, 2025. This clears the path for the long-awaited award and implementation of the SEWP VI Government-Wide Acquisition Contract (GWAC), expected to be worth over $60 billion.

Key Details:

• Protests Withdrawn (March 13, 2025):
  • Copia Consulting Group, LLC (File No: B-423306.3)
  • Next Step Group, Inc. (File No: B-423306.2)
  • Adaptivestack Technologies, Inc. (File No: B-423306.1)
• Previous Impact:
  • These protests had caused uncertainty and delay in NASA’s evaluation and award process for SEWP VI.
• Current Status:
  • No active protests remain
  • NASA can move forward with final evaluations, award decisions, and post-award activities
• Next Steps:
  • NASA will likely finalize contract awards in the coming weeks, barring any new legal or procedural challenges

The withdrawal of the final protests signals momentum and certainty for offerors awaiting SEWP VI awards. Small and mid-sized businesses pursuing prime or subcontracting roles under this massive GWAC can now focus on onboarding, teaming strategies, and preparing for task order competitions. The end of the protest phase is a strong signal that the contract vehicle will be operational soon, and contractors should align their capabilities and marketing efforts accordingly. This is a high-value opportunity for firms in the IT, cybersecurity, cloud, and managed services sectors.

GSA’s Overhaul of FedRAMP Contingent on Automation and Agency Buy-In

The General Services Administration (GSA) is pushing forward with a comprehensive overhaul of the Federal Risk and Authorization Management Program (FedRAMP) in 2025, but progress is heavily dependent on the adoption of automation and increased agency participation. The modernization initiative, aligned with the FedRAMP Authorization Act, aims to improve the security assessment process for cloud services and streamline approvals—but agencies’ slow uptake of automation tools and processes could hinder its effectiveness.

Key Details:

• FedRAMP Modernization Goals:
  • Implement automation for security reviews and continuous monitoring.
  • Increase efficiency in approving and renewing cloud service providers (CSPs).
  • Reduce duplicative paperwork and manual reporting requirements.
• Dependency on Agencies and Vendors:
  • Agencies must adopt new tooling and provide structured feedback to GSA.
  • Cloud vendors are expected to integrate with the updated compliance framework, particularly the Open Security Controls Assessment Language (OSCAL) format.
• Challenges Identified:
  • Many agencies still use legacy manual processes or hesitate to adopt OSCAL.
  • Without broader automation adoption, FedRAMP timelines may remain slow, especially for small or new CSPs.
• Regulatory Context:
  • GSA is working with the Office of Management and Budget (OMB) and Department of Homeland Security (DHS) to align FedRAMP’s modernization with wider federal cybersecurity goals under EO 14028.

FedRAMP’s modernization could be a game-changer for small businesses and cloud service providers seeking to enter or expand in the federal IT space. If automation tools and streamlined workflows are adopted government-wide, the cost and time to achieve FedRAMP authorization could decrease, reducing barriers for small and emerging tech companies. However, continued agency resistance to automation poses risks of stagnation, especially for vendors depending on faster approvals to grow. Contractors should stay informed, adopt OSCAL-friendly processes, and engage with the GSA’s FedRAMP PMO to track updates and participate in pilot programs.

SCOTUS Greenlights Release of Foreign Aid Funds to Government Contractors

On March 5, 2025, the Supreme Court of the United States (SCOTUS) denied certiorari in a high-stakes case that had halted foreign aid disbursements to U.S. government contractors. The Court’s refusal to hear the appeal effectively ends the legal blockade and permits the Department of State and USAID to resume funding for overseas development, humanitarian, and global health programs. This decision brings long-awaited relief to contractors whose operations were frozen during the legal dispute.

Key Details:

• SCOTUS Decision Date: March 5, 2025 – Denied certiorari, allowing the lower court ruling to stand.
• Legal Background:
  • The case challenged the State Department’s use of cooperative agreements, questioning whether they bypassed federal procurement rules.
  • The D.C. Circuit upheld these agreements, validating them as compliant with the Federal Grant and Cooperative Agreement Act.
• Impact of the Legal Hold:
  • Foreign aid funds were frozen for months.
  • Major international development contracts were delayed or paused.
  • Contractor cash flow and project timelines were significantly disrupted.
• Effect of the Ruling:
  • Resumption of payments to contractors.
  • Restart of overseas aid programs across health, democracy-building, and humanitarian sectors.
  • Legal confirmation that cooperative agreements do not violate procurement statutes.

This decision is a major win for contractors operating in the foreign assistance space. With aid disbursements unblocked, contractors can resume paused projects, recover delayed revenue, and re-engage international partners. It restores cash flow certainty, particularly for small businesses supporting USAID or State Department efforts abroad. Perhaps most importantly, the ruling affirms the legitimacy of cooperative agreements as a federal funding mechanism, providing greater legal clarity and operational stability in non-traditional government contracting environments.

DoD Eliminates Equal Employment Opportunity (EEO) Clauses from Future Contracts

On March 4, 2025, the Department of Defense (DoD) issued a policy memo instructing all contracting officers to remove Equal Employment Opportunity (EEO) clauses and provisions from new solicitations and contracts. The memo, signed by John Tenaglia, Director of Defense Pricing and Contracting Policy, directs the DoD to stop enforcing President Lyndon B. Johnson’s 1965 executive order that originally mandated federal contractors to promote equal employment and prevent workplace discrimination.

This policy aligns with the Trump administration’s “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” Executive Order, which revokes several DEI and affirmative action-related requirements for federal contractors.

Key Details:

• Policy Date: Memo issued March 4, 2025
• Changes Implemented:
  • Eliminates EEO-related clauses from new contracts and solicitations
  • Removes requirements related to:
    • Prohibition of segregated facilities
    • Compliance reporting
    • Affirmative action in construction
    • On-site compliance evaluations
    • Visa denial notifications
• Grandfathering Rule:
  • Contracts set to expire within six months and without extension options do not need modification
• Context:
  • This is distinct from DEI program bans, which are still under federal court review
  • Title VII of the Civil Rights Act still applies—contractors must continue non-discriminatory employment practices

This policy shift reduces administrative and compliance burdens for defense contractors, especially those frequently handling affirmative action plans or workforce analyses. While some may see cost savings, others express concern about potential legal confusion, especially around what federal, state, and local requirements still apply. Contractors must still comply with Title VII, and those operating in states with their own EEO or DEI laws need to seek legal guidance before altering internal policies. The removal of longstanding EEO clauses may also lead to employee lawsuits if companies mistakenly eliminate protections still mandated elsewhere, highlighting the need for cautious implementation.

New Legal Rule Protects Government Contractors from Costly Delays and Frivolous Lawsuits 

In a significant shift for federal litigation, a new legal standard issued in March 2025 now requires plaintiffs to post monetary security (a bond) before obtaining injunctions against the federal government. The decision, arising from recent federal court rulings and executive directives, aims to discourage frivolous lawsuits and last-minute injunctions that delay critical government contracting activities, particularly those involving national security, healthcare, and infrastructure.

Previously, plaintiffs—often advocacy groups or competitors—could halt federal programs without financial consequences if their claims were ultimately unsuccessful. This rule change reinstates the bond requirement under Federal Rule of Civil Procedure 65(c) for injunctions, even in cases against government agencies.

Key Details:

• New Requirement: Plaintiffs must post a bond when seeking a temporary restraining order (TRO) or preliminary injunction against the federal government.
• Background:
  • In prior years, many federal courts waived this requirement, citing a “public interest” exception.
  • This leniency allowed plaintiffs to block procurement awards, federal programs, and contract execution without financial risk.
• Legal Rationale: Courts now emphasize that injunctions impose real costs on the government and third-party contractors, including lost time, resource shifts, and halted operations.
• Scope of Impact: Applies across federal procurement, including defense, healthcare, foreign aid, infrastructure, and cybersecurity contracts.

This rule change is a major win for federal contractors, who often face contract delays or terminations due to last-minute legal actions brought by competitors or advocacy groups. By requiring plaintiffs to put up financial security, courts are adding a deterrent against frivolous lawsuits and encouraging more careful, well-founded challenges. Contractors can now proceed with awarded contracts with greater confidence and fewer disruptions. For small businesses, in particular, this change reduces the risk of delayed payments or halted project work, which can severely impact cash flow and business operations. However, contractors should still track potential protests closely and consult legal counsel, as litigation remains a key aspect of federal procurement dynamics.