Smith Currie Oles' Procurement Playbook: Contracting in the Age of Trump Updates

Federal government contracting is impacted each time there is a change in administration in the White House. This year will be no different. We will be monitoring daily the Executive Orders and policy changes coming from the Trump administration that will impact you and your projects. You will likely receive a flurry of information as we keep you updated on these important changes that will be coming frequently over the next several days.

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White House Rescinds Office of Management and Budget Memorandum M-25-13 Suspending Federal Assistance Funding (Contracting in the Age of Trump Update #10)
January 29, 2025
In a brief memorandum dated January 29, 2025, the White House rescinded OMB Memorandum M-25-13, which suspended funding for federal assistance programs. This rescission comes after public confusion concerning the specific programs that would be affected by the suspension and U.S. District Judge Loren AliKhan’s order issuing a temporary stay of the directive. Read More…

Judge Blocks Office of Management and Budget Suspension of Federal Assistance Spending (Contracting in the Age of Trump Update #9)
January 29, 2025
A federal judge from the U.S. District Court for the District of Columbia issued a temporary restraining order blocking the Office of Management and Budget’s (OMB) hold on federal assistance programs minutes before the directive went into effect on Tuesday, January 28, 2025 at 5:00 PM EST. Read More…

Department of Defense and Office of Management and Budget Put the Brakes on Huge Swath of Federal Contract and Assistance Spending (Contracting in the Age of Trump Update #8)
January 28, 2025
The Department of Defense (DoD) has temporarily suspended the award of new contracts, except for emergency contracts, while reviewing compliance with the latest presidential directives. The freeze on DoD contracts is effective immediately as of January 27, 2025. The DoD has not announced how long the suspension will last, Read More…

Executive Orders Related to DEIA Revoked (Contracting in the Age of Trump Update #7)
January 22, 2025
In alignment with promises throughout his campaign, on January 21, 2025, President Donald Trump signed an executive order titled “Ending Illegal Discrimination and Restoring Merit-Based Opportunity.” This order mandates the termination of all diversity, equity, inclusion, and accessibility (DEIA) initiatives within federal agencies, asserting that such programs violate civil rights laws and undermine traditional American values of hard work, Read More…

President Trump’s First Day in Office Brings Sweeping Changes to DEI Policies (Contracting in the Age of Trump Update #6)
January 22, 2025
On January 20, 2025, President Donald Trump issued an executive order titled “Ending Radical and Wasteful Government DEI Programs and Preferencing.” This order came after the President’s sweeping executive order, “Initial Rescissions Of Harmful Executive Orders And Actions,” which revoked approximately 78 Biden executive orders and policies. Read More…

A Juxtaposition of Environmental Policies (Contracting in the Age of Trump Update #5)
January 21, 2025
On President Trump’s first day in office, he issued an Executive Order (“Initial Rescissions of Harmful Executive Orders and Actions,”) revoking approximately 78 Biden Executive Orders and policies. (Trump’s Executive Orders are yet to have numbers affixed to them due to their recent nature.)
It should come as no surprise that President Trump’s first mass rescission has a substantial impact on environmental policies, Read More…

Court of Federal Claims Holds That Project Labor Agreement Requirement in Construction Contracts Violates Competition in Contracting Act
January 21, 2025
On January 19, 2025, the Court of Federal Claims issued its decision in MVL USA, Inc. et al. v. United States, holding that the project labor agreement (“PLA”) requirement initiated in Executive Order 14063 and implemented by FAR Subpart 22.5 violates the Competition in Contracting Act (“CICA”). Read More…

Revocation of Biden Executive Order 14055 – Nondisplacement of Service Workers (Contracting in the Age of Trump Update #4)
January 21, 2025
On his first day in office, January 20, 2025, Pres. Trump revoked Pres. Biden’s November 18, 2021, Executive Order 14055, Nondisplacement of Service Workers.
For those of you who are service contractors, you may know the sorry history of this concept. Basically, Democrats love it. Republicans hate it. Read More…

Massive Number of Biden Procurement Policies Revoked on First Day of Trump Administration – What Should Contractors Do? (Contracting in the Age of Trump Update #3)
January 21, 2025
On January 20, 2025, within hours of taking the oath of office, Pres. Trump issued a flurry of executive orders, many of which revoked the policies of his predecessor, Pres. Biden. One such Executive Order, Initial Rescissions of Harmful Executive Orders and Actions (these executive orders of Pres. Read More…

Contractors Beware! Check the Immigration Status of your Workforce (Contracting in the Age of Trump Update #2)
January 20, 2025
While President Trump has not yet begun signing executive orders, it appears doubtless that pursuant to his campaign and inaugural speech, deportations of many people here illegally will begin immediately. It is therefore incumbent upon contractors to check that their workers are here legally. President Trump has called sacred his two rules of “ Buy American and Hire American“ so all contractors should check the status, Read More…

A Sigh of Relief for Federal Contractors Accompanies the FAR Council’s Withdrawal of Proposed Greenhouse Gas Rule and Proposed Pay Equity and Transparency Rule (Contracting in the Age of Trump Update #1)
January 20, 2025
This month, the FAR Council announced the withdrawal of two pivotal proposed rules for federal procurement. These now-abandoned potential requirements in the Federal Acquisition Regulation arose from two Executive Orders from the Biden administration.
Executive Order 14030 (“Climate-Related Financial Risk”), issued on May 20, Read More…