Understanding the Proposed Updates to Organizational Conflict of Interest Rules

On January 15, the Department of Defense, GSA, and NASA published proposed rules that would implement the Preventing Organizational Conflicts of Interest in Federal Acquisition Act. The Act was enacted on December 27, 2022. It directs the Federal Acquisition Regulatory (FAR) Council to:

  • update regulatory definitions related to specific types of organizational conflicts of interest (OCIs), including unequal access to information, impaired objectivity, and biased ground rules;
  • provide updated guidance and illustrative examples related to relationships of contractors with public, private, domestic, and foreign entities that may result in OCIs; and
  • provide illustrative examples of situations related to the potential for OCIs.

The proposed changes implement the Act by moving OCI regulations to a new subpart, FAR part 3, and substantially revising and clarifying current OCI regulations.

The focus of the proposed rule is to update and strengthen policies to prevent OCIs in federal contracting.

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Pentagon aims to accelerate acquisition of new tech through software-contracting change

Buyers must default to rapid-acquisition processes long used by DIU, SecDef memo orders.

The Pentagon must default to rapid acquisition processes when buying software, from business systems to weapons components, the defense secretary said in a Thursday memo. The move is a “big deal,” one expert told Defense One, because it will push the Defense Department to stop spending considerable money and time trying to build its own software and instead go to the marketplace for products that might already exist.

“While the commercial industry has rapidly adjusted to a software-defined product reality, DoD has struggled to reframe our acquisition process from a hardware-centric to a software-centric approach,” Defense Secretary Pete Hegseth wrote in the March 6 memo. “Software is at the core of every weapon and supporting system we field to remain the strongest, most lethal fighting force in the world.”

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FSRS.gov to Retire This Week: How-To Videos Available, Register Now for Weds Training

The General Services Administration will retire FSRS.gov the evening of March 6, 2025. This means that the system will be unavailable and no new data can be entered into FSRS.gov.  Subaward reporting will then become available in SAM.gov on March 8, 2025.  

We advise the following actions:

• FSRS.gov users who already have a SAM.gov account should take action now to connect their two accounts.
• FSRS.gov users who do not currently have a SAM.gov account should take action now to create a new account at SAM.gov.
• All users will need to be granted the correct role and permission in SAM.gov by their SAM.gov entity administrator before being able to access the new subaward reporting capabilities after March 8.

To help users prepare for the change, we are holding a live training session on Wednesday at 1:00PM EST to walk through what subaward reporting will look like in SAM.gov.  Register now for the March 5 training.

Additionally, GSA just posted two previous trainings and five how-to videos to the IAE playlist on GSA YouTube that users can access and watch now (including a bulk upload training).

For the latest information about subaward reporting in SAM.gov and links to relevant information, please visit our information page on SAM.gov.

Pentagon seeks to shift $50B in planned funding to new priorities in FY26

Breaking Defense obtained a list of the 17 priority categories that are to be financially protected in FY26.

WASHINGTON — Secretary of Defense Pete Hegseth has ordered a review of the department’s fiscal 2026 budget plans in order to shift funds from legacy programs towards President Donald Trump’s priorities, including border security and the Iron Dome for America.

The goal: Find roughly $50 billion, or 8 percent of the FY26 plan, and reprioritize it.

“Secretary Hegseth has directed a review to identify offsets from the Biden Administration’s FY26 budget that could be realigned from low-impact and low-priority Biden-legacy programs to align with President Trump’s America First priorities for our national defense,” acting Deputy Secretary of Defense Robert Salesses said in a Wednesday night statement.

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