Government Contracts Report – Week of February 17, 2020

VA’s Rule of Two and GSA Leases

According to a decision from GAO last month, the VA’s Rule of Two does not require GSA to set-aside lease procurements it conducts on behalf of the VA for veteran-owned businesses.

DOD Increases CPSR Dollar Threshold

DOD has amended DFARS creating a dollar threshold for contractor purchasing system reviews (CPSR). Under FAR 44.302(a), an ACO determines whether a contractor’s sales to the government will exceed $25M during the next twelve months and if so performs a review to determine whether a CPSR is needed. DoD has increased the dollar threshold triggering a review for a possible CPSR to $50M for its contractors.

Fair Chance Act Compliance Now Required

The Fair Chance Act was signed into law as part of the NDAA for FY 2020 late last year. The Act prohibits federal contractors that have openings for positions within the scope of federal contracts, as well as all federal agencies, from inquiring about or seeking criminal history information from an applicant until after a conditional job offer has been extended. There are exceptions for positions in law enforcement, national security, and those handling classified information. For initial violations of the Act, contractors will receive a notice and warning of violation; for subsequent violations, suspension of payments owed under the contractor or suspension and civil penalties can result.


Attorney Kristi Morgan AronicaOur government contracts briefs, reports, and articles are published by Attorney Kristi Morgan Aronica. She serves as counsel to government contractors and subcontractors throughout Texas and nationally.