ARTICLE · 28 JUNE 2012

New Suspension And Debarment Bill: Positive Changes, Causes For Concern

Perkins Coie LLP

Explore more from Perkins Coie LLP

In a recent client update, we discussed proposed legislation, entitled the Comprehensive Contingency Contracting Reform Act of 2012.

United StatesGovernment, Public Sector

In a recent client update, we discussed proposed legislation, entitled the Comprehensive Contingency Contracting Reform Act of 2012, that would provide for the automatic suspension of a contractor in a variety of situations, including when the federal government merely alleges fraud against a contractor in a civil or criminal proceeding related to a federal contract. We noted that the proposed legislation was roundly criticized by representatives of the affected agencies: the Department of Defense, the Department of State and the U.S. Agency for International Development. See "Shift to 'Automatic' Ineligibility Determinations Poses Increased Risk to Federal Contractors".

Now a new bill changes the automatic suspension into an automatic referral to suspension and debarment officials for final decision making.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Related Articles

NRC Proposes Expanding Exemptions From Materials Licensing: Implications For Licensees, Agreement States

United StatesGovernment, Public Sector

Greenberg Traurig

D.C. Circuit Rules Pentagon Can Exclude Anthropic From Supply Chain

United StatesGovernment, Public Sector

Taft, Stettinius & Hollister LLP

Heads Up: COINS Act Proposal Takes Aim At Biotech And AI Investment In China

GlobalGovernment, Public Sector

Goodwin Procter LLP

Fifth Circuit Holds That CFIUS Does Not Preempt Texas State Law Restricting Foreign Investment

United StatesGovernment, Public Sector

Tropical Storm Isaias Could Strengthen Into A Hurricane: What Gulf Coast Residents Should Know

United StatesGovernment, Public Sector

Morgan & Morgan

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Government, Public Sector
- Government Contracts, Procurement & PPP

See more popular content from

Government, Public Sector

SBA Extends Deadline For Comments On Historic Overhaul Of Size Standards

The Small Business Administration has extended the comment period for two proposed rules that could dramatically reshape federal government contracting by significantly expanding the pool of entities eligible for small business set-aside procurements. With some size standard thresholds proposed to increase as much as tenfold, these changes would fundamentally alter the makeup of the small business contractor base.

United StatesGovernment, Public Sector

Crowell & Moring LLP

BIOSECURE Act Update: Court Enjoins WuXi AppTec’s 1260H Designation, but Strategic and Compliance Clocks Keep Running

The U.S. District Court for the District of Columbia has preliminarily enjoined the Department of War from enforcing WuXi AppTec's Section 1260H designation, finding the agency misread its evidence on state and military affiliation. However, this ruling does not close alternative pathways to biotechnology company of concern (BCC) designation under the BIOSECURE Act, and earlier supply-chain restrictions continue to drive near-term compliance decisions with a critical June 30, 2027 deadline for sub-tier supp

United StatesGovernment, Public Sector

Greenberg Traurig

Sanctions Update: October 19, 2026

This comprehensive sanctions update examines the US delisting of Venezuelan politician Jorge Rodriguez amid diplomatic negotiations and energy sector expansion, while tracking global sanctions developments including new US restrictions on Iranian banks, UK measures targeting hostile Iranian activities, EU designations for sanctions circumvention, and China's proposed export controls on advanced technologies.

GlobalGovernment, Public Sector

FMCSA MOTUS Implementation – Common Motor Carrier Concerns

The Federal Motor Carrier Safety Administration launched MOTUS in May 2026, replacing legacy registration platforms and fundamentally changing how motor carriers, freight brokers, and surface freight forwarders handle operating authority applications and license maintenance. While designed to combat fraud and streamline registration activities, the transition has created significant user experience challenges that threaten operating authority status and customer relationships for transportation service prov

United StatesGovernment, Public Sector

Benesch, Friedlander, Coplan & Aronoff LLP

When Can Congress Refuse To Seat A Duly-Elected Candidate?

Never. In 1969, the U.S. Supreme Court ruled that the Speaker of the House could not exclude a duly-elected candidate for the U.S. House of Representatives.

United StatesGovernment, Public Sector

Holland & Knight

Massachusetts’ 2026 Ballot Questions: What Clients Need To Know

Massachusetts voters will decide nine statewide ballot questions in November 2026 that could fundamentally reshape the state's legal, regulatory, and fiscal landscape. These measures address government transparency, election reforms, housing development, marijuana regulation, firearms laws, and state revenue limits, with implications extending far beyond Election Day to implementation, regulation, and ongoing policy debates.

United StatesGovernment, Public Sector

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

Weekly Sanctions Update: October 13, 2026

The US has authorized Russian diesel imports while simultaneously expanding sanctions against the International Criminal Court and Iran's shadow fleet. These developments highlight tensions between energy security concerns and sanctions enforcement, as international partners express divergence over US policy directions.

GlobalGovernment, Public Sector

Weekly Sanctions Update: September 14, 2026

The Treasury Department intensifies economic pressure on Iran through Operation Economic Outcast, suspending aviation licenses and sanctioning dozens of entities while implementing a presumption of denial for Iran-related transactions. Meanwhile, new enforcement actions target Chinese cybercrime platforms, Ecuadorian terrorist organizations, and Israeli settlers, as Congress considers comprehensive Russia-Iran sanctions legislation.

GlobalGovernment, Public Sector

The Analysts' Brief: The US-Russia Diesel Deal

The Trump administration's October 2025 diesel deal with Russia promises temporary sanctions relief to ease US fuel prices before midterm elections, but analysts question whether the limited supply will meaningfully impact global markets or represent a lasting shift in US-Russia relations. The agreement has already strained transatlantic partnerships and US-Ukraine cooperation while raising compliance uncertainties for businesses navigating evolving sanctions regimes.

GlobalGovernment, Public Sector

DOJ Continues DEI False Claims Act Enforcement With $25 Million Accenture Settlement

The Department of Justice announced a $25 million settlement with Accenture Federal Services over allegations that the company violated the False Claims Act by falsely certifying compliance with anti-discrimination requirements while allegedly using race or sex in hiring, promotion, and access to professional development programs. This marks the third major DEI-related FCA enforcement action in 2026, following similar settlements with IBM and Deloitte.

United StatesGovernment, Public Sector

Bass, Berry & Sims PLC