Ralph C. Thomas III

Senior Counsel
Ralph C. Thomas III

Ralph C. Thomas III

Senior Counsel
Washington T: 202.836.8467 F: 202.327.6137
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Ralph C. Thomas III

Ralph C. Thomas III

SENIOR COUNSEL
rthomas@whitefordlaw.com
WASHINGTON
T: 202.836.8467
F: 202.327.6137
Biography
BIOGRAPHY
Mr. Thomas specializes in Government Contracts Law and has substantial experience in all phases of the field. He has represented government contractors before federal courts, federal agencies and arbitration tribunals in contract terminations, bid protests, size protests, contract claims and dispute resolution. He also advises firm teams on government contracts issues arising in mergers and acquisitions, intellectual property and corporate structuring.
 
Mr. Thomas is the immediate past Chair of the Government Contracts Section of the Federal Bar Association (FBA), which recognized him with its "Outstanding Leader Award." He was also named the 2025 "Lawyer of the Year" in Government Contracts by the District of Columbia Bar.

In academia, Mr. Thomas taught Government Contracts Law at the University of Virginia's School of Continuing and Professional Studies and spent five years as an Adjunct Professor of Law for five years at Concord School of Law (now a part of Purdue University Global), teaching in its LL.M Program. He also served as a Clinical Law Instructor at George Washington University Law School. He has drafted and reviewed numerous joint venture, subcontract and teaming agreements, including cross-border agreements involving UK companies, and has published more than 80 articles on issues related to government contracts.
 
On small business issues, Mr. Thomas served 13 years as Associate Administrator of NASA's award-winning Small and Disadvantaged Business Utilization Office and now serves as Vice-Chair of the Small Business and Other Socioeconomic Programs Committee of the ABA’s Public Contracts Law Section.  He has testified in Congress more than 30 times on issues facing small government contractors and has spoken frequently at small business conferences nationwide, including as an invited panelist at a 2023 White House contracting summit. He has addressed conferences in Europe, the Middle East, Southeast Asia and South America

Mr. Thomas’s government service was recognized with the Presidential Rank of Distinguished Executive, awarded to roughly one percent of federal Senior Executives (President George W. Bush) and the Presidential Rank of Meritorious Executive, awarded to five percent of Senior Executives (President Bill Clinton).He is a UK Solicitor admitted to the Senior Courts of England and Wales and a member of the U.K.'s Procurement Lawyers Association. A military veteran, he served four years in the U.S. Air Force and achieved the rank of Staff Sergeant.
 

Recognitions

  • Federal Bar Association (FBA), “Outstanding Section and Division Leader Award" as Chair of the Government Contracts Section, 2025
  • D.C. Bar, Lawyer of the Year in Government Contracts, 2025
 

Memberships & Activities

  • Chair: Federal Bar Association, Government Contracts Section
  • Vice-Chair: American Bar Association, Public Contract Law Section - Committee on Small Business & Other Socioeconomic Programs
  • Member: District of Columbia Bar Association
  • Member: U.K. Procurement Lawyers Association
  • Member: London Court of International Arbitration
  • Member: Law Society of England and Wales
  • Member: Supreme Court Historical Society
INSIGHTS

Moderator, "Practical Impact of the New SBA Recertification Regulations on the M&A Industry", Federal Bar Association Webinar, (March 2025).

Panelist, "Equity in Government Contracting: Realizing Opportunities and Overcoming Barriers", White House Contract Summit, (September 2023).

Panelist, “New Legislation and the Construction Industry” and “ Governmental Compliance Solutions in Federal Contracting” National Association of Minority Contractors (November 2022).

Speaker, "New SBA Rules for Subcontracting, JV Past Performance and Other Trends in Government,” Howard County Chamber BizBreakfast (September 2022).

ARTICLES

September 8, 2025

Client Alert: SBA Proposes New Rule To Increase Receipts-Based Size Standards

Do you have clients that are classified as small businesses? Small business classifications are determined by the SBA under what are called “North American Industry Classification System (NAICS) codes.” The first two numerical digits describe the overall industry, and the succeeding numbers in the code break down the business industry more specifically. The size standards represent “caps” on each industry, which cannot be exceeded if the business is to be categorized as “small.” The size standard is the average of the previous five full years that an entity has been in business.
February 5, 2024

Client Alert: Administration’s Attempt to Freeze all Federal Financial Assistance is Stalled by Court Ruling

On January 27, 2025, the new Administration’s Office of Management and Budget (OMB) issued a Memorandum ordering a total freeze on “all federal financial assistance” that could be targeted under his previous executive orders pausing funding for a wide range of priorities — from domestic infrastructure and energy projects to diversity-related programs and foreign aid. However, the attorneys general of 22 states immediately filed a complaint for injunction against that directive in Federal Court.
 
February 4, 2025

Client Alert: The Quiet Storm

The new Administration’s recent Executive Order making DEI programs in Federal agencies illegal as to race, gender and sexual orientation very notably did not mention eliminating affirmative action requirements for individuals with disabilities. The reason is probably because affirmative action plans for individuals with disabilities are statutory in nature and, thus, cannot be eliminated by an executive order. Specifically, Section 503 of the Rehabilitation Act of 1973 (29 U.S.C. 701 et seq.) requires Federal contractors with contracts valued at over $50,000 to adopt affirmative action plans to recruit, hire, promote, and retain employees with disabilities.
January 8, 2025

Client Alert: SBA Final Rule Expected to Spur Increased Small Government Contractor M&A Activity In 2025

On December 17, 2024, the U.S. Small Business Administration (“SBA”) issued a Final Rule (“Rule") that will dramatically change the landscape for the Merger and Acquisition (“M&A”) market for both large and small businesses. Under the new Rule, an acquiring firm will no longer be eligible to bid on set-aside or reserved orders under a Multiple Award Contract (MAC) if, following a merger, acquisition, or sale, the acquired firm makes a disqualifying recertification (“no longer small”). Currently, a concern remains eligible to bid set-aside or reserved orders under a MAC after the M&A deal, but the agency cannot count the orders toward its small business goals. The new Rule, which goes into effect on January 17, 2026, is expected to spur an increased level of M&A during 2025.
November 1, 2023

Client Alert: SBA Reopens 8(a) Program After Court Decision

A recent federal district court decision in the case of Ultima Servs. Corp. v. U.S. Dep’t of Agric. resulted in an injunction against the U.S. Small Business Administration (SBA), prohibiting the agency from applying a rebuttable presumption of social disadvantage based on being a part of the Black, Hispanic, Asian Pacific, and Native American races in the administration of its 8(a) Business Development Program.
November 21, 2022

Client Alert: Defense Department Establishes Sole Source Set-Aside Program For ESOPs

The Department of Defense (DOD) recently announced a pilot program to incentivize contracting with employee-owned businesses, otherwise known as ESOPs, or companies owned by an Employee Stock Ownership Program. Authorized by Section 874 of the National Defense Authorization Act for FY 2022 (Pub. L. 117-81), this program will allow DOD to award certain follow-on contracts on a non-competitive basis to ESOPs.  Contracting Officers (CO) supporting this program will be able to award a follow-on contract for the continued development, production, or provision of products or services that are the same or substantially similar to those procured by DOD under a previous contract with a “qualified business.” The qualifying ESOP companies are not required to be a small business.

NEWSLETTERS

July 27, 2023

Government Contracts Newsletter - July 2023

R&D Contractors Implore Congress To Restore Crucial Tax Incentive

Incumbent’s Non-Compete Agreements Did Not Lead To Successful Protest

Contractor Turns Size Protest Into Federal Claims Act Case Resulting In Favorable Federal Court Decision, Upending Sba’s Traditional Method For Calculating Size Of A Small Business

New Initiative Launched To Increase Federal Contracting With Small Disadvantaged Businesses

 
June 23, 2023

Government Contracts Newsletter - June 2023

Government Contractors: Start Preparing For Greenhouse Gas Emissions Reporting

TikTok on Contractor Devices Banned By Interim Rule

If Government Uses Written Materials For Debriefing, Do Not Open Emails Sent After Normal Business Hours

Contractors:  Keep Your S.A.M. Registration Up To Date Or Lose The Contract You Won
May 19, 2025 - Honors & Awards

Ralph Thomas Named Gov Con Lawyer of the Year by DC Bar

The District of Columbia Bar has named Ralph C. Thomas III Lawyer of the Year in Government Contracts. The award recognizes members who stand out in their respective practice areas by exhibiting excellence in the profession, as well as dedication to the mission of the D.C. Bar and D.C. Bar Communities.