DoD Issues Class Deviation For Small Business Joint Venture Offerors Until SAM Is Updated to Account for Recent FAR Revisions
Client Alert | 1 min read | 10.27.22
On October 26, 2022, the Department of Defense published a class deviation establishing alternative procedures for verifying the small business size and status of joint venture offerors. This class deviation is necessary because, effective October 28, 2022, the Federal Acquisition Regulation has been updated to include new certifications for use by joint venture offerors in FAR solicitation provisions 52.212-3 and 52.219-1—via a FAR update on which Crowell previously reported. Due to a lag in system implementation in the System for Award Management (SAM) and in the interface between SAM and the Small Business Administration, SAM will not reflect the new representations immediately. As such, DoD’s class deviation provides language for contracting officers to use in solicitations in lieu of relying on SAM for size and status certifications of joint venture offerors.
Contacts
Insights
Client Alert | 4 min read | 05.01.26
Federal Court Blocks Trump Administration Policies Restricting Wind and Solar Permitting
A coalition of regional clean energy trade associations — including RENEW Northeast, Alliance for Clean Energy New York, Southern Renewable Energy Association, and Interwest Energy Alliance — along with the Green Energy Consumers Alliance (GECA), filed suit in December 2025 against the Department of the Interior (DOI), the Bureau of Land Management, the Bureau of Ocean Energy Management, the U.S. Fish and Wildlife Service (USFWS), and the Army Corps of Engineers. The complaint alleged that five agency actions, issued in response to a series of executive orders and presidential memoranda beginning on January 20, 2025, violated the Administrative Procedure Act (APA) by arbitrarily halting or restricting federal permitting for wind and solar energy projects. Plaintiffs sought a preliminary injunction to halt enforcement of these policies while the litigation proceeds. See Renew Northeast, et al. v. U.S. Dep’t of Interior, et al., No. 25-cv-13961-DJC, (D. Mass. Apr. 21, 2026) ECF Dkt. 89.
Client Alert | 2 min read | 05.01.26
New Executive Order Promoting Fixed Price Contracting: What It Means for Federal Contractors
Client Alert | 8 min read | 05.01.26
Pre-Approved: ICO Publishes Guidance on "Recognised Legitimate Interests”
Client Alert | 6 min read | 04.29.26
CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)
