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DPAS Regs Updated and Expanded

Client Alert | less than 1 min read | 08.15.14

On August 14, 2014, Commerce's Bureau of Industry and Security issued a final rule revising the Defense Priorities and Allocations System (DPAS) Regulations. Among other changes, the final rule (1) expands the scope of DPAS coverage by adding homeland security and critical infrastructure protection/restoration activities as reasons that rated orders may be issued; (2) adds language clarifying that recipients of rated orders have delegated authority to place ratings on contracts or orders with lower-tier contractors, subcontractors, and suppliers; and (3) reduces the time for written follow-up if a party is unable to comply with a rated order. 

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Client Alert | 2 min read | 12.29.25

FYI – GAO Finds Key Person “Available” Despite Accepting Employment with a Different Company

GAO’s key personnel rule is well-known—and often a source of frustration— amongst government contractors.  Proposed key personnel who become “unavailable” prior to contract award—especially where they have accepted employment with a different company—may doom an offeror’s proposal by rendering it noncompliant with solicitation requirements.  But GAO’s recent decision in FYI – For Your Information, Inc., B-423774, B-423774.2 (Dec. 19, 2025) provides some potential relief from that rule. ...