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“(Don’t) Let the Chips Fall Where They May”:  FAR Council Previews Proposed Rule Implementing the Covered Semiconductor Prohibition  

Government Contracts Legal Forum

The statutory deadline for a final rule is December 23, 2025, and the semiconductor prohibition will go into effect on December 23, 2027. Semiconductor Provenance The ANPR rightly acknowledges the practical challenges of compliance with the Section 5949 prohibitions given the pervasiveness of semiconductors and the opacity of supply chains.

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Friday Flash 04/12/2024

The Coalition for Government Procurement

The strategy outlines how DoD plans to fully implement its Zero Trust cybersecurity strategy departmentwide by fiscal year (FY) 2027. The clause at FAR 52.204-30 – Alternate 1, Federal Acquisition Supply Chain Security Act Orders – Prohibition, is incorporated by full text into the solicitation (and subsequent awarded contracts).

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Friday Flash 08/16/2024

The Coalition for Government Procurement

According to CMS, 15 more Part D drugs will be selected for negotiation for 2027 by February 1, 2025. The proposed changes to the DFARS are primarily to: Add references to the CMMC 2.0 The negotiated pricing is the first in a series that will be conducted through the Medicare Drug Price Negotiation Program.

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The FY 2024 National Defense Authorization Act: Key Provisions Government Contractors Should Know

Government Contracts Legal Forum

This provision of the NDAA seems targeted at bridging the communication gap between the agencies by requiring that the parties to a proposed transaction over the HSR threshold provide a copy of their HSR filing directly to DoD. The provision also limits non-availability waivers to 36 months.

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Friday Flash 12/13/2024

The Coalition for Government Procurement

As CISA has noted , [an SBOM] has emerged as a key building block in software security and software supply chain risk management. SBOMs are defined by CISA as a formal record containing the details and supply chain relationships of various components used in building software.

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Friday Flash 12/20/2024

The Coalition for Government Procurement

MAPS is a multiple-award, indefinite-delivery/indefinite-quantity contract that is set to replace the ITES-3S and RS3 contracts in 2027. Request for Feedback on Proposed Rule Raising Procurement Thresholds The Coalition plans to submit comments on a November 29 proposed rule, “Inflation Adjustment of Acquisition-Related Thresholds.”