Sheila Armstrong represents a broad range companies in all aspects of government contracting including FAR-based contracts, grants and other financial assistance agreements and Other Transaction Agreements (OTAs). She routinely counsels both prime and subcontractors in a variety of contractual and civil settings. Sheila's experience includes proposal preparation, contract negotiation, subcontracting, teaming arrangements, intellectual property rights in government contracts, contract compliance, audits, investigations, mandatory disclosures, and procurement fraud. She also routinely provides support to clients on novation and due diligence issues. Sheila frequently advises clients with respect to General Services Administration (GSA) and Veterans Affairs (VA) Federal Supply Schedule contracts.
Clients turn to Sheila for her knowledge of developing and maintaining corporate compliance programs. In this area, she conducts compliance reviews, training, and internal investigations, and advises clients on required disclosures under the Federal Acquisition Regulation (FAR) and 2 CFR Part 200. She has represented clients before defense and civilization agencies, including the US Department of Justice (DOJ), the General Accountability Office (GAO), the US Department of Defense (DoD), the GSA, and various Suspension and Debarment Officials.
Complementing her contracting work, Sheila provides counsel on foreign sourcing issues and regularly advises on compliance with the Buy American Act, Trade Agreements Act, and other foreign sourcing restrictions applicable to federal contracts.
Sheila is an active member of the American Bar Association’s Public Contracts Law Section, serving in a leadership role as council member, co-chair of the Procurement Division, vice chair of Finance, and vice chair of the Commercial Products and Services Committee. She frequently assists with comment letters submitted on behalf of the American Bar Association relating to new and updated regulatory changes.
A leading software provider in a referral from the GSA Office of Inspector General to the DOJ for allegations relating to providing unqualified personnel and underreporting contract sales
A client in CNCS Office of Inspector General investigation resulting from a self disclosure of potential improper use of grant funds
A defense contractor in a DoD Office of Inspector General disclosure and associated investigation by the US Army Criminal Investigation Command (CID) resulting from first article test failure of defense product at an Army testing lab. Resulted in repair of prior products delivered but no monetary penalty
A leading services contractor in a referral from the Library of Congress Inspector General to the DOJ for allegations relating to providing unqualified personnel
A leading technology company in a qui tam action relating to noncompliance with GSA contract requirements
A client in a DoD investigation and follow-on referral to the DOJ resulting from alleged defective products delivered to various branches of the military
Conducted numerous investigations relating to potential noncompliance with GSA contract requirements, including commercial sales practice disclosures, Price Reductions Clause compliance, and potential overcharging
Numerous companies in mandatory disclosures at the DoD, GSA, and other agencies
Numerous companies in audits, investigations, and qui tam matters relating to alleged noncompliance with foreign sourcing requirements including the Buy American Act and Trade Agreements Act
Numerous companies in pre-award and post-award GSA Office of Inspector General audits
Numerous companies in presentations to Suspension and Debarment Officials for the US Army, US Air Force, US Navy, and General Services Administration, among others
Conducted several investigations related to internal whistleblower/hotline complaints
Conducted many compliance reviews to assess internal controls, policies, and procedures relating to government contracts
Routinely provide advice in due diligence related to acquisitions and divestitures of government contractors
University of San Diego School of Law, 2001, J.D., cum laude
University of Nevada, Las Vegas, 1999, B.S.
District of Columbia
US District Court for the Northern District of Texas
Awards and Affiliations
Member, Government Contracts Editorial Advisory Board, Law360 (2018–present)
Council Member, Public Contract Law Section of the American Bar Association (2018–present)
Co-Chair, Procurement Division (2020-2021)
Vice Chair, Commercial Products and Services Committee (2013, 2014, 2018–present)
Vice Chair, Finance (2018–2020)
Co-Chair, Commercial Products and Services Committee (2014–2017)