Cara A. Wulf

/My focus

I focus my practice on government contracts and regulatory compliance. I have extensive experience assisting clients across the full spectrum of federal, state, and local public procurement challenges, including navigating compliance with the Federal Acquisition Regulation (FAR), the Defense Federal Acquisition Regulation Supplement (DFARS), and other agency-specific procurement regulations. My practice includes designing and implementing comprehensive corporate compliance programs tailored to the diverse and complex requirements of government contracting and federal financial assistance. I counsel companies on how to navigate a variety of domestic preference rules and regulations, including the Buy American Act (BAA), the Trade Agreements Act (TAA), “Buy America” Department of Transportation statutes, and the Build America, Buy America (BABA) Act.

My work also includes assessing eligibility and compliance with the terms of various programs administered by the Small Business Administration (SBA), addressing issues regarding cost allowability, allocability, and reasonableness, and the Cost Accounting Standards (CAS), and counseling on the intellectual property requirements of the Bayh-Dole Act.

In addition to my counseling and compliance work, I regularly assist clients in drafting and negotiating prime and subcontract terms and conditions, teaming agreements, and joint venture arrangements. I also advise on preparing and negotiating requests for equitable adjustments, managing issues arising under design-build construction contracts—to include addressing differing site conditions—as well as responding to contract terminations and providing strategic responses to contracting officer final decisions (COFDs). My litigation practice encompasses bid protests, claims, and other disputes before federal agencies, the GAO, courts, and administrative tribunals such as the Armed Services Board of Contract Appeals (ASBCA).

I am experienced on both sides of government contracting. Before private practice, I spent several years working for multiple US Department of Defense agencies. I started my career as an Assistant District Counsel for the US Army Corps of Engineers. In that capacity, I regularly advised on contractor compliance with the FAR and DFARS and on matters of contract administration, to include disputes with prime contractors, and acted as agency counsel in contract and other litigation matters before the ASBCA, the Court of Federal Claims, and US District Courts. I also served as an Assistant Counsel and Trial Attorney for the Defense Contract Management Agency (DCMA). In those roles, I reviewed and advised on necessary revisions to Contracting Officer Final Decisions (COFDs) and actively litigated a full caseload of contractor appeals from COFDs valued in the tens of millions of dollars.

/Looking ahead

Government procurement is undergoing a time of dramatic change. The Federal Acquisition Regulation (FAR) is undergoing a complete overhaul, which is rolling out across agencies and the new requirements are starting to appear in new procurements. The Department of Defense is also transforming its acquisition strategy, and several key authorities and acquisition reforms in the Fiscal Year 2026 National Defense Authorization Act are poised to have significant impacts on the way the DOD does business in the years to come. In addition, ongoing impacts from the Trump Administration’s drive toward efficiency to government operations and periodic shutdowns has resulted in instability, terminations, and other potential impacts to contractors’ businesses.

/Insights

Cara is a thought leader in the area of government contracts. She routinely writes and speaks on a diverse array of topics, including government contracting basics, the domestic preference statutes and regulations, developments in cybersecurity, intellectual property in government contracting, cost issues, and requests for equitable adjustment and claims.

Publications

• “Buy American and Made in USA: One slogan, two compliance systems,” Federal News Network, April 3, 2026
• “Feature Comment: The New Madness? CMMC-Mania—It’s Arrived!” The Government Contractor, September 26, 2024
• “Viewpoint: Pentagon Brings Clarity to Buy American Requirements,” National Defense Magazine, June 6, 2024
• “Les Misérables—Contractors and Agencies Struggle to Navigate Build America, Buy America Requirements One Year Later,” The Government Contractor, December 21, 2022
• “Eureka! Long-Awaited Updates to iEdison Present Opportunities and Challenges for Reporting of Government-Funded Inventions,” Law360, August 1, 2022
• “Arbitrary Factors May Hinder Buy American Rule Changes,” Law360, August 9, 2021
• “Keep American Businesses Workin’ 9 to 5—Bipartisan Changes to Buy American Requirements in Federal Procurement,” The Government Contractor, February 25, 2021
• “Just What the Doctor Ordered—Remedies for Federal Contractors During the COVID-19 Pandemic and Beyond,” The Government Contractor, April 30, 2020
• “New Year, New Rules—Changes Are Coming to the FAR’s Small Business Subcontracting Limits and Nonmanufacturer Rule,” The Government Contractor, January 30, 2019

Speaking Engagements

• “You Say You Want a Revolution: Navigating the FAR Overhaul,” Society for American Military Engineers Joint Engineer Training Conference (SAME JETC), May 20, 2026
• “Procurement Innovation in 2026: Defense Acquisition Transformation and the NDAA,” Society for American Military Engineers Joint Engineer Training Conference (SAME JETC), May 19, 2026
• “Negotiating Terms and Conditions,” Public Contracting Institute, March 25, 2026
• “NDAA & Procurement: Change is Coming,” 2026 SAME Capital Week, March 24, 2026
• "Build America, Buy America Compliance: Protecting Federal Infrastructure Funding from Contract to Certification,” myLawCLE, March 20, 2026
• “Performance of Government Contracts,” Federal Publications Seminars, March 11, 2026
• “Protecting Federal Funding in a Time of Uncertainty,” NCMA Boston, March 11, 2026
• “Procurement Process,” Federal Publications Seminars, March 10, 2026
• “Introduction to Government Contracts and Associated Regulations,” Federal Publications Seminars, March 3, 2026
• “Performance of Government Contracts,” Federal Publications Seminars, February 17, 2026
• “RFO Updates on FAR 12 and 15—What You Should Know,” Federal Publications Seminars, February 12, 2026
• “Critical Takeaways from the Revolutionary FAR Overhaul—FAR Parts 12 and 15,” Deltek, December 11, 2025
• “Protecting Federal Contracts and Grants Amid Executive Disruption,” Barbri, December 4, 2025
• “Accelerating Domestic Sourcing Post-Tariffs: Ensuring Continued Buy American Compliance,” SAME Federal Small Business Conference, November 19, 2025
• “IIJA, BABA, Other Recent Developments in Buy American Compliance,” Federal Publications Seminars, October 28, 2025
• “Negotiating Terms & Conditions,” Public Contracting Institute, October 22, 2025
• “The BAA/TAA and DOD,” Federal Publications Seminars, October 21, 2025
• “The Fundamentals of the Trade Agreements Act,” Federal Publications Seminars, October 14, 2025
• “The Fundamentals of the Buy American Act,” Federal Publications Seminars, October 7, 2025
• “Strategies for Addressing DCAA Audit Findings,” Deltek, September 3, 2025
• “Becoming A Prime Contractor,” Public Contracting Institute, August 7, 2025
• “REAs, Claims and Disputes,” Federal Publications Seminars, July 30, 2025
• “Performance of Government Contracts,” Federal Publications Seminars, July 23, 2025
• “Procurement Process,” Federal Publications Seminars, July 16, 2025
• “A Guide to the Buy American and Trade Agreements Act,” Federal Publications Seminars, July 10, 2025
• “Introduction to Government Contracts and Associated Regulations,” Federal Publications Seminars, July 9, 2025
• “The Evolving Impact of AI in Government Contracting, Deltek, February 13, 2025
• “A Guide to the Buy American and Trade Agreements Act,” Federal Publications Seminars, February 11, 2025
• “Contract or Collapse? Navigating the DoD’s CMMC Rule for Success,” ArcherHall, January 30, 2025
• “Build America Buy America: Strategies for Success In Compliance,” CIRAS, January 23, 2025
• “Selected Cost Principles—Professional and Consultant Costs,” Deltek, December 12, 2024
• “Primes and Subs: Partners in Buy America(n) Compliance,” SAME Federal Small Business Conference, November 22, 2024
• “Strategies for Success in Federal Subcontracting,” Women Impacting Public Policy, November 13, 2024
• “REAs, Claims, and Disputes,” Federal Publications Seminars, October 31, 2024
• “Performance of Government Contracts,” Federal Publications Seminars, October 24, 2024
• “Procurement Process,” Federal Publications Seminars, October 17, 2024
• “Introduction to Government Contracts and Associated Regulations,” Federal Publications Seminars, October 10, 2024
• “Hazards to Contractors Entering the US Supply Chain by Subcontract,” Public Contracting Institute, August 1, 2024
• “Buy America(n)–A Deep Dive Into Domestic Preference Regulations by Agency,” Federal Publications Seminars, July 24, 2024
• “A Guide to the Buy American and Trade Agreements,” Federal Publications Seminars, July 9, 2024
• “Preparing for the Future: Breach and AI,” Federal Publications Seminars, June 25, 2024
• “Supply Chain Management and Cybersecurity Updates,” Federal Publications Seminar, June 18, 2024
• “Understanding DoD Assessment Requirements,” Federal Publications Seminars, June 11, 2024
• “2024: FAR Part 39, Acquisition Of Information Technology,” Jennifer Schaus & Associates, June 7, 2024
• “Understanding and Navigating CPARS,” Deltek, June 6, 2024
• “Introduction to Cybersecurity,” Federal Publications Seminars, June 4, 2024
• “Understanding Domestic Preference in Federal Infrastructure Contracts,” Iowa State University CIRAS, April 25, 2024
• “Why Bid Protests Matter and How To Make Them Count,” Native Hawaiian Organizations Association, April 22, 2024
• “Negotiating Terms and Conditions,” Federal Contracting Institute, April 2, 2024
• “A Guide to the Buy American Act and Trade Agreements Act,” Federal Publications Seminars, March 12, 2024
• “Buy America(n)—A Deep Dive Into Domestic Preference Regulations by Agency,” Federal Publications Seminars, March 5, 2024
• “A Guide to the Buy American and Trade Agreements Act,” Federal Publications Seminars, February 8, 2024
• “Dive into Travel Costs – FAR Part 31.205-46,” Public Contracting Institute, February 1, 2024
• “IIJA, BABA, Other Recent Developments in Buy American Compliance,” Federal Publications Seminars, January 31, 2024
• “An Introduction to Protecting Intellectual Property as a Government Contractor,” Deltek, January 25, 2024
• “The BAA/TAA and DOD,” Federal Publications Seminars, January 24, 2024
• “The Fundamentals of the Trade Agreements Act,” Federal Publications Seminars, January 17, 2024
• “The Fundamentals of the Buy American Act,” Federal Publications Seminars, January 10, 2024
• “A How-To Guide to Successful Federal Contracting: Advice to Primes and Subs,” TargetGov, January 9, 2024
• “Supply Chain Management and Cybersecurity Updates,” Federal Publications Seminars, December 14, 2023
• “Understanding DoD Assessment Requirements,” Federal Publications Seminars, December 7, 2023
• “White-Collar Issues in the Construction World: Compliance and Prevention,” Construction Super Conference, November 29, 2023
• “Cloud Security and FedRAMP,” Federal Publications Seminars, November 16, 2023
• “Introduction to Cybersecurity Fundamentals of Cybersecurity and Regulatory Updates 2023,” Federal Publications Seminars, November 9, 2023
• “New Build America, Buy America Domestic Sourcing Requirements for Federally Funded Projects,” Strafford, November 7, 2023
• “Elements of a Bid Protest October 2023,” Federal Publications Seminars, October 25, 2023
• “Success in Subcontracting: Drafting and Negotiating Federal Subcontracts,” Women Impacting Public Policy ChallengeHER, October 24, 2023
• “Federal Infrastructure Series: Buy America(n) in Infrastructure Contracting,” Public Contracting Institute, October 19, 2023
• “Federal Infrastructure Series: Common Claim Issues in Construction Contracting Part 2,” Public Contracting Institute, October 5, 2023
• “Selected Cost Principles—Advanced Strategies for Compliance,” Deltek, September 28, 2023
• “Protecting Intellectual Property in Government Contracts—A Practical Guide,” Women Impacting Public Policy, ChallengeHER, September 28, 2023
• “Federal Infrastructure Contracting Series: Formation,” Public Contracting Institute, September 14, 2023
• “A Primer on Build America, Buy America- Strategies for Success in Compliance,” Iowa State University CIRAS, August 8, 2023
• “A Guide to the Buy American Act and Trade Agreements Act,” Federal Publications Seminars, July 27, 2023
• “REAs, Claims and Disputes,” Federal Publications Seminars, July 19, 2023
• “Negotiating Subcontractor Terms and Conditions,” Public Contracting Institute, July 13, 2023
• “Performance of Government Contracts,” Federal Publications Seminars, July 12, 2023
• “Buy America(n)—A Deep Dive Into Domestic Preference Regulations by Agency,” Federal Publications Seminars, July 10, 2023
• “Procurement Process,” Federal Publications Seminars, June 28, 2023
• “Introduction to Government Contracts and Associated Regulations,” Federal Publications Seminars, June 21, 2023
• “GovCon101: Terms and Conditions,” Public Contracting Institute, June 12, 2023
• “IP in Government Contracting,” Public Contracting Institute, June 8, 2023
• “Changes and Equitable Adjustments in Government Contracting,” Federal Publications Seminars, May 9, 2023
• “Buy America(n)—A Deep Dive Into Domestic Preference Regulations by Agency,” Federal Publications Seminars, April 13, 2023
• “Infrastructure Investment & Jobs Act & Other Recent Developments in BA Compliance,” Federal Publications Seminars, April 4, 2023
• “The BAA/TAA and DOD,” Federal Publications Seminars, March 28, 2023
• “Becoming A Prime Contractor,” Public Contracting Institute, March 23, 2023
• “The Fundamentals of the Trade Agreements Act,” Federal Publications Seminars, March 21, 2023
• “Protecting IP Under DOD Contracts—A Practical Guide,” NCMA Boston, March 15, 2023