Off the Shelf

This week on Off the Shelf, Jeff Koses, senior procurement executive at the General Services Administration (GSA) shares the vision and goals for the Revolutionary Federal Acquisition Regulation (RFO). 

As an introduction to the discussion, Koses explains the role the FAR Council plays in the rule-making process, including how, OMB, GSA, DoW, and NASA work together to draft FAR rules consistent with statutes and executive orders.

He then explains how the FAR Council used deviations to meet the ambitious timelines set forth by the administration.

In addition, Koses highlights the shift to reliance on guidance documents like the Practitioner’s Albums to support the acquisition workforce.

Finally, Koses discusses the RFO changes and the significant regulatory changes that streamline the process and reduce burdens for government and industry.

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Jonathan Aronie, partner at Sheppard Mullin, joins Off the Shelf for an engaging discussion of GSA’s proposed AI clause and President Trump’s executive order, “Addressing DEI Discrimination By Federal Contractors.” 

GSA’s AI Clause establishes a governance framework and establishes an allocation of rights and responsibilities between the government, contractor, and any AI service provider supporting the contractor.  

The AI clause takes an approach that raises questions regarding its consistency with commercial practice and potential burdens on the private sector that may inhibit access to cutting edge, commercial AI solutions. 

Aronie analyzes the AI clause’s key provisions, and provides his insights and analysis of the new DEI executive order, which mandates new contract language addressing DEI discrimination. 

Finally Aronie outlines what contractors need to know regarding, the timing, scope, and mechanics of the executive order’s new contractual obligations on DEI.  

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This week on Off the Shelf, Moshe Schwartz, president of Etherton & Associates, joins host Roger Waldron to discuss the geopolitical landscape facing the nation and how it driving defense acquisition policy reform. 

Schwartz shares his insights on procurement, logistical and supply chain challenges and opportunities driving the Department of War’s (DoW’s) restructuring/reform of acquisition operations. 

He also highlights some under the radar provisions of the NDAA, and dissects the readiness challenge facing DoW, sharing his insight the key management changes that are improving readiness along with what more can be done.  

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This week on Off the Shelf, Brian Friel from BD Squared, addresses the state of governmentwide contracting. 

Friel gives a postmortem on CIO-SP4 including lessons learned and pitfalls to avoid when utilizing a self-scoring evaluation model. 

He also gives an update on OASIS+ and the IT GWACs, including NASA SEWP VI, POLARSIS, Alliant 3, and highlights the Alliant’s programs major step forward in announcing the first set of awardees. 

Other topics included the impact of the RFO on governmentwide contracting, including the new FAR Part 8’s framework for mandatory contracts, and FAR Part 16’s revision that allows Blanket Purchase Agreements under Multiple Award contracts other than the Schedules.

Finally, Friel gives his thoughts on OASIS+ and the Army’s MAPS procurement.

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This week on Off the Shelf, Ken Dodds, executive vice president and general counsel for Coalition for Common Sense in Government Procurement, joins host Roger Waldron to discuss some of the most important small business rules impacting procurement.

In the wake of the Department of War’s memo on pass-throughs and reviewing set-asides over $20 million, Dodds shares his insights on framework and limitations on subcontracting under small business set-asides contracts and the government’s corresponding focus when reviewing subcontracts under set-asides and want constitutes a potential pass-through situation. He provides the nuances inherit in these rules that play an understated role in management of small business programs.  

Finally Dodds gives his thoughts on a host of current procurement topics, including GSA’s Reseller RFI, commercial practices and the RFO.  

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This week on Off the Shelf, Bill Gormley, president of the Gormley Group, and Alan Thomas, founder of Alpha Tango Strategies, recap the 2025 year in federal procurement and look ahead to 2026.  

Gormley and Thomas cover a host of topics, including the impact of the Department of Government Efficiency (DOGE), the RFO, consolidation efforts at GSA, the cancellation of CIO-SP4, and the GSA Reseller Request for Information (RFI). 

They also share their thoughts and analysis on the Revolutionary FAR Overhaul (RFO) with the formal rulemaking looming in 2026. 

Finally Gormley and Thomas discuss the establishment of the Office of Centralized Acquisition Services (OCAS) in GSA’s Federal Acquisition Service. 

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Joanne Woytek, NASA SEWP program director, joins Off the Shelf to discuss the performace of the NASA SEWP V contract over the past decade.

She provides an overview of the program's key metrics, including customer profile, current year and overall performance, types, and scope of mission support for customer agencies. 

Woytek also discusses the role of data -- explaining how NASA SEWP supports customer agencies through procurement data collection and analysis, and she gives an update on NASA SEWP VI.  

The evolution of technology and the NASA SEWP approach to meeting customer needs are another discussion topic.  

Finally, Woytek shares her thoughts on the keys to management success in leading the program for over two decades. 

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This week on Off the Shelf, Jessica Tillipman, associate Dean for Government Procurement Law at The George Washington University Law School, grades the Revolutionary FAR Overhaul (RFO) and outlines the risks and opportunities of Artificial Intelligence (AI) in government procurement operations. 

Tillipman gives her assessment of the RFO, highlighting key changes and the overall impact. Listen in to hear her grades and analysis of the RFO! 

She also provides a tutorial understanding AI architecture through a “Wedding Cake” model.

Finally, Tillipman discusses the key procurement policy considerations surrounding the use of AI, including addressing potential conflicts of interest, ensuring protection of data, and fostering competition. 

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Zach Terwilliger and Alex Canizares, partners with Vinson & Elkins, join Off the Shelf, for a wide-ranging discussion of the current compliance environment for government contractors.

Terwilliger discusses current Department of Justice priorities relating to criminal and civil enforcement and what government contractors should be focusing on. 

He and Canizares also provide their insights regarding the Trump administration’s approach to the False Claims Act highlighting the interplay with procurement polices like CMMC. 

The duo also shares their thoughts regarding the administration’s Civil Rights Fraud initiative and its implications for contractors.

Terwilliger and Canizares also share key FCA trends and provide their best practices for compliance. 

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This week on Off the Shelf, Rob Burton, partner at Crowell & Moring LLP, provides his insights and analysis of the Revolutionary FAR Overhaul (RFO), the ongoing restructuring of procurement operations across government, and the implications and opportunities for government contractors.

Burton shares his thoughts on key RFO changes, including the new MAS ordering procedures, FAR Part 19, and the FAR Part 12 changes. 

He also offers a clear, concise, and compelling outline of the goals for the RFO and the move to consolidate procurement operations across government.   

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