SBA’s July 2013 Small Business Subcontracting Revisions Finally Implemented in the FAR
Client Alert | less than 1 min read | 07.21.16
On July 14, 2016, DoD, GSA, and NASA published a final rule implementing numerous updates to the FAR to account for regulatory changes affecting the small business subcontracting requirements made by the SBA dating back to July 2013. These changes, which become effective November 1, 2016, range from requiring prime contractors to assign NAICS codes to subcontracts, to providing contracting officers the discretion to establish subcontracting goals at the order level of IDIQ contracts, to protecting subcontractors’ ability to discuss payment or utilization matters with the contracting officer.
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Client Alert | 3 min read | 11.21.25
On November 7, 2025, in Thornton v. National Academy of Sciences, No. 25-cv-2155, 2025 WL 3123732 (D.D.C. Nov. 7, 2025), the District Court for the District of Columbia dismissed a False Claims Act (FCA) retaliation complaint on the basis that the plaintiff’s allegations that he was fired after blowing the whistle on purported illegally discriminatory use of federal funding was not sufficient to support his FCA claim. This case appears to be one of the first filed, and subsequently dismissed, following Deputy Attorney General Todd Blanche’s announcement of the creation of the Civil Rights Fraud Initiative on May 19, 2025, which “strongly encourages” private individuals to file lawsuits under the FCA relating to purportedly discriminatory and illegal use of federal funding for diversity, equity, and inclusion (DEI) initiatives in violation of Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (Jan. 21, 2025). In this case, the court dismissed the FCA retaliation claim and rejected the argument that an organization could violate the FCA merely by “engaging in discriminatory conduct while conducting a federally funded study.” The analysis in Thornton could be a sign of how forthcoming arguments of retaliation based on reporting allegedly fraudulent DEI activity will be analyzed in the future.
Client Alert | 3 min read | 11.20.25
Client Alert | 3 min read | 11.20.25
Client Alert | 6 min read | 11.19.25
