Monthly Archives: September 2024

NO SHUTDOWN FOR NOW: WHEN CAN FEDS AND THEIR CONTRACTORS EXPECT “FINAL” APPROPRIATIONS?

All federal agencies will remain open through December 20th per a Continuing Resolution (CR) passed September 25th.  Although doing business under a CR is no one’s first choice, the government and its suppliers are used to it by now.  The specter of a shutdown has also been at least temporarily removed.

When can federal agencies and the companies that do business with them expect to see “final” appropriations for the 2025 Fiscal Year?  Here are three scenarios that could help those involved in the business of government plan appropriately.

  1. Kamala Harris is Elected President, but Neither Party Holds Both Chambers of Congress:  Under this scenario, there would be little point in pushing final appropriations actions out into the 2025 calendar year. Harris had some level of input into the Biden budget and a new Congress that looks similar to the current one couldn’t change much from what’s already been done.  Congressional leaders have said that they would like to get appropriations passed by the end of the calendar year, which is the new “normal”.  This election outcome makes that more likely.

Shutdown Chances:  Low

  1. Donald Trump is Elected and Republicans Maintain Control of at Least one Chamber: A Trump Presidency, coupled with at least some sort of Republican Congressional power base, increase the chances that final appropriations would be delayed into calendar year 2025.  Republicans would want to give their president a chance to have some impact on spending measures and, if a new Congress was thought to be more sympathetic, that would likely resurrect some version of an earlier House proposal to extend a CR into March.  A short shutdown, just to show people they can do it, is not totally out of the question.  Final appropriations could come at about the same time they did in FY’24 – late winter or early spring.

Shutdown ChancesModerate

  1. Kamala Harris is elected President and the Democrats Control Both Chambers: House Republicans would likely push very hard in a lame duck session to assert their current influence, knowing that it would end in the new Congress.  A relatively small number of members could force a shutdown to protest anticipated increases in government spending.   Democrats, though no fans of a shutdown, may also want to delay final appropriations action until a new Congress under their control can weigh in.  This would again likely push action into the late winter or early spring.

Shutdown ChancesHigh

Government agencies and their contractor partners should watch election outcomes closely. Not only will they provide a roadmap on policy priorities and legislation for several years, they will also have a potentially significant impact on when and how FY’25 appropriations are finally enacted.

NoteA similar article appeared last week on the Washington Technology website

FOUR TAKE-AWAYS FROM LAST WEEK’S FBI/DCIS RAID ON A CONTRACTOR

Most companies have heard by now that one of the very largest GSA Schedule contractors was raided last week by a joint FBI/Defense Criminal Investigative Service (DCIS) task force.  While raids are rare, they do occur and can significantly disrupt your business and attract unwanted attention.  Here are four tips contractors should follow to minimize armed federal agents suddenly appearing at their door.

1.  Carefully Vet Your Business Partners:  The raided company is reportedly not the main target of the FBI/DCIS investigation.  Rather, it is a company that they partner with. Remember, you are “your brother’s brother”, at least according to the feds.  Companies must do a thorough Read more

AGENCIES PUBLISH PLANS FOR AI COMPLIANCE & GOVERNANCE

The Departments of Defense, Homeland Security, and Health and Human Services are among the agencies that have published their plans on how they will comply with AI guidance issued earlier this year by the Office of Management and Budget.  OMB directed agencies to post their initial compliance plan publicly on their website or publish a determination that the agency doesn’t use or anticipate using any AI covered by the memo.  The DoD Chief Digital and Artificial Intelligence Officer (CDAO) is that department’s AI governance body.  It is comprised of a wide range of DOD activities, including acquisition policy as well as the Principal Deputy Read more

IT’S TRAINING TIME AGAIN!!

Magic happens at midnight tonight!  We ring out the old fiscal year and ring in the new!  That means that now is the best time of year for your company to get trained up on the latest rules and changes you may have missed while you were out selling.  Allen Federal has a full array of training available on everything from compliance issues to regulatory updates, to established best business practices.  To find out what we can do for you contact us today at info@allenfederal.com and we’ll customize a training course that will be informative AND entertaining!!

OUR PREDICTIONS ON A SHUT DOWN AND FY’25 APPROPRIATIONS

Although it will be close, the federal government will likely not shut down for any significant amount of time at the start of the new fiscal year.  The most contractors and their customers could expect is a short 24-48 shutdown, most likely including at least one weekend day.  That’s Allen Federal’s prediction as of right now.  Never mind side shows on voting security and tangential issues the Senate and White House would like to add, the Continuing Resolution should be mostly “clean” and will likely last into mid-December.  That is not to say that final Read more