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Partial Government Shutdown Does Not Toll Filing Deadlines at GAO, Court, or Boards

Client Alert | 1 min read | 12.26.18

Contractors with upcoming protest or litigation filing deadlines take note – the partial government shutdown will not impact filing deadlines at the Government Accountability Office (GAO), the U.S. Federal Courts, the Armed Services Board of Contract Appeals (ASBCA) or Civilian Board of Contract Appeals (CBCA), all of which remain open. GAO has indicated that it will operate as normal during the shutdown and will not toll any deadlines for private parties, but will grant extensions for those agencies impacted by a lapse in appropriations. The U.S. Federal Courts, including the U.S. Court of Federal Claims, are not currently impacted by the shutdown but may have limited resources if the shutdown goes beyond January 11, 2019. Agency lawyers impacted by the shutdown may seek relief from deadlines on a case by case basis. The ASBCA and CBCA remain open and are accepting filings during the shutdown.

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Client Alert | 2 min read | 07.15.26

CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations

As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights....

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