WASHINGTON, D.C. — September 2025 — Gordon Rees Scully Mansukhani (GRSM) has released its latest Government Contracts Legal Update and Podcast, providing an in-depth review of the most pressing developments impacting federal and state contractors. From significant regulatory adjustments by the Federal Acquisition Regulatory (FAR) Council to court rulings affecting small business eligibility, this update delivers critical guidance for contractors navigating today’s evolving procurement environment.
Contractors can also tune into The Essential GovCon Brief podcast on Spotify or YouTube, where GRSM attorneys expand on these issues and discuss practical implications for businesses across industries.
On August 27, 2025, the FAR Council finalized a rule adjusting numerous acquisition thresholds to account for inflation, effective October 1, 2025. The five-year review required by 41 U.S.C. § 1908 ensures purchasing power keeps pace with rising costs.
Key changes include:
Raised from $10,000 to $15,000 for general purchases; contingency operations thresholds increased as well, including overseas ($35,000 → $40,000).
Increased from $250,000 to $350,000, with even higher ceilings for contingency and humanitarian operations.
Higher approval levels now apply when awarding contracts without full and open competition, including an increase in Senior Procurement Executive review from $100 million to $150 million.
Adjusted upward to $2.5 million.
Raised to $900,000 for prime contracts and $2 million for construction contracts.
Ceiling increased to $9 million for simplified acquisitions.
Bernard explained that these changes particularly affect contingency operations — deployments, emergencies, or overseas missions where rapid procurement is critical. Contracting officers will now have expanded flexibility to meet urgent demands.
The FAR Council also issued a final rule on August 7, 2025, clarifying the timing of System for Award Management (SAM) registration. Contractors must be registered at two specific points only:
Continuous registration between those two events is no longer required.
For small businesses, this removes a significant administrative burden. “Contractors no longer need to worry about losing eligibility because of minor, mid-process lapses in registration,” GRSM noted. However, active registration remains mandatory throughout contract performance until final payment.
A recent decision by the U.S. Court of Federal Claims underscores the importance of proving Service-Disabled Veteran-Owned Small Business (SDVOSB) eligibility as of the bid date.
In Veteran Elevated Solutions, LLC v. United States, the court remanded an SBA Office of Hearings and Appeals (OHA) ruling that upheld Armstrong Elevator Company’s SDVOSB status. The court criticized OHA for failing to meaningfully address evidence related to:
Because OHA relied heavily on older files and limited testimony without fully analyzing the new evidence, the court found its decision deficient. Contract performance has been stayed pending OHA’s reevaluation.
The takeaway for contractors: SDVOSB control must be substantive and continuous, supported by detailed records of ownership, management, and operational authority.
These updates represent both opportunities and risks:
GRSM’s Government Contracts team advises contractors to review their compliance frameworks now, update internal policies, and ensure they are prepared for audits, protests, or new procurements under the revised thresholds.
Originally reported by JD Supra.
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