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Stephanie Barna

Stephanie Barna draws on over three decades of U.S. military and government service to provide advisory and advocacy support and counseling to clients facing policy and political challenges in the aerospace and defense sectors.

Prior to joining the firm, Stephanie was a senior leader on Capitol Hill and in the U.S. Department of Defense (DoD). Most recently, she was General Counsel of the Senate Armed Services Committee, where she was responsible for the annual $740 billion National Defense Authorization Act (NDAA). Additionally, she managed the Senate confirmation of three- and four-star military officers and civilians nominated by the President for appointment to senior political positions in DoD and the Department of Energy’s national security nuclear enterprise, and was the Committee’s lead for investigations.

Previously, as a senior executive in the Office of the Army General Counsel, Stephanie served as a legal advisor to three Army Secretaries. In 2014, Secretary of Defense Chuck Hagel appointed her to be the Principal Deputy Assistant Secretary of Defense for Manpower and Reserve Affairs. In that role, she was a principal advisor to the Secretary of Defense on all matters relating to civilian and military personnel, reserve integration, military community and family policy, and Total Force manpower and resources. Stephanie was later appointed by Secretary of Defense Jim Mattis to perform the duties of the Under Secretary of Defense for Personnel and Readiness, responsible for programs and funding of more than $35 billion.

Stephanie was also previously the Deputy General Counsel for Operations and Personnel in the Office of the Army General Counsel. She led a team of senior lawyers in resolving the full spectrum of issues arising from Army wartime operations and the life cycle of Army military and civilian personnel. Stephanie was also a personal advisor to the Army Secretary on his institutional reorganization and business transformation initiatives and acted for the Secretary in investigating irregularities in fielding of the Multiple Launch Rocket System and classified contracts. She also played a key role in a number of high-profile personnel investigations, including the WikiLeaks breach. Prior to her appointment as Deputy, she was Associate Deputy General Counsel (Operations and Personnel) and Acting Deputy General Counsel.

Stephanie is a retired Colonel in the U.S. Army and served in the U.S. Army Judge Advocate General’s Corps as an Assistant to the General Counsel, Office of the Army General Counsel; Deputy Staff Judge Advocate, U.S. Army Special Forces Command (Airborne); Special Assistant to the Assistant Secretary of the Army (Manpower & Reserve Affairs); and General Law Attorney, Administrative Law Division.

Stephanie was selected by the National Academy of Public Administration for inclusion in its 2022 Class of Academy Fellows, in recognition of her years of public administration service and expertise.

In March 2025, the European Union published a white paper for European Defense Readiness 2030, which identifies defense needs and envisions a massive €800 billion four-year “ReArm Europe” investment plan. This initiative is a significant step change from the EU’s prior defense industrial strategy and earlier funding programs.

Rearming Europe would be financed by €150 billion in EU common debt made available as loans to Member States and €650 billion in national spending that EU fiscal rules would not constrain. This new package is intended to support EU Member State efforts to ramp-up defense capabilities and, if implemented, it would effectively double the overall amount of defense spending in Europe. Covington is working with clients in defense industry sectors across the wider West to maximize business opportunities created by this new funding.

Unleashing Europe’s Defense Potential

Given the “rapid deterioration of the geopolitical context and rising tensions,” the white paper pledges to unleash the EU’s resources and latent industrial and technological power on defense. It aims to swiftly increase support for Ukraine and deter Russia’s further aggression, while reducing dependency on U.S. military support. Further, it paves the way to tackle long-term security threats such as the “systemic” challenge posed by China and growing hybrid threats.

The EU seeks to support collaborative capability development among Member States, to enhance coordination and generate economies of scale.  Here, joint procurements will be a privileged tool, notably by setting up a European Military Sales Mechanism. This mechanism will support manufacturing capabilities and deliver more complex projects through aggregated demand and increasing predictability for the sector. To do so, it will incentivise long-term common procurements, as envisioned also by the European defense common procurement act.

In the near-term, investments and procurements on defense industrial capabilities will focus on rebuilding Europe’s depleted stocks of military hardware and equipment. Key capability domains include air and missile defense, artillery systems, ammunition and missiles, drones and counter-drone systems, military mobility, artificial intelligence, quantum, cyber & electronic warfare, strategic enablers and critical infrastructure protection.

To quickly expand its defense capabilities, Europe is also exploring strengthening its defense industrial collaboration with trusted partners such as the Republic of Korea, Norway, and Japan (with which the EU signed Security and Defence Partnerships last year), as well as its traditional allies and partners, such as the United Kingdom and the United States.Continue Reading Rearming Europe with Trusted Partners

On April 9, 2025, President Trump issued an Executive Order (“EO”), “Modernizing Defense Acquisitions and Spurring Innovation In the Defense Industrial Base,” that may have significant implications for federal government contractors doing business with the Department of Defense (“DoD”), and particularly those with touchpoints to Major Defense Acquisition Programs (“MDAPs”).

The EO requires DoD to take a number of actions, including:

  • Within 60 days (i.e., June 8th), the Secretary of Defense must submit to the President a plan to reform the DoD acquisition process to eliminate inefficiencies.  The plan must prioritize commercial solutions and the use of Other Transactions Authority (“OTA”) agreements and Rapid Capabilities Office mechanisms.  The plan must also eliminate redundant tasks and approvals, centralize decision-making, and incorporate effective risk management for all acquisition programs through a governance structure referred to as a Configuration Steering Board. 
  • Under no specified timeline, DoD is generally directed to revise internal regulations and implementation guidance — including the DoD Financial Management Regulation and the Defense Federal Acquisition Regulation Supplement — utilizing the principle from the “Unleashing Prosperity Through Deregulation” EO (Jan. 31, 2025) that for every new regulation proposed, ten existing regulations should be repealed.
  • Within 90 days (i.e., July 8th)the Secretary of Defense must review all MDAPs and consider for “potential cancellation” programs that are: (1) more than 15% behind schedule; (2) more than 15% above cost; (3) “unable to meet key performance parameters”; or (4) otherwise not aligned with DoD mission priorities.  Following this review of MDAPs, the Secretary of Defense will conduct a similar review for all remaining major systems.
  • Within 120 days (i.e. August 7th)the Secretary of Defense, in collaboration with the Military Departments, must propose a plan to overhaul the defense acquisition workforce by restructuring performance metrics, assessing workforce sizing requirements, and deploying expert-led field training teams to enhance familiarity with innovative acquisition authorities.  These reforms are intended to incentivize prudent risk-taking and expand the workforce’s fluency in commercial solutions and adaptive acquisition strategies.  
  • Within 180 days (i.e., October 6th), the Secretary of Defense, acting through the Deputy Secretary of Defense, the Secretaries of the Military Departments and the Joint Chiefs of Staff, must complete a comprehensive review of the Joint Capabilities Integration and Development System (“JCIDS”), with the aim of streamlining and accelerating acquisition.[1] 

We address the EO’s directives for acquisition process reform and MDAP review in greater detail below. Continue Reading Trump Administration Issues Executive Order Aimed At Modernizing Defense Acquisitions And Spurring Innovation

Under a newly enacted law, beginning June 30, 2026, defense contractors risk losing all future contracts with the Defense Department if they engage outside consultants that lobby for certain Chinese companies. On December 23, 2024, President Biden signed the National Defense Authorization Act (“NDAA”) for Fiscal Year (“FY”) 2025

Continue Reading New Law Appears to Restrict Defense Contractors from Retaining Consultants Who Lobby for Chinese Military Companies

This is the first blog in a series covering the Fiscal Year 2025 National Defense Authorization Act (“FY 2025 NDAA”).  This first blog will cover: (1) NDAA sections affecting acquisition policy and contract administration that may be of greatest interest to government contractors; (2) initiatives that underscore Congress’s commitment to strengthening cybersecurity, both domestically and internationally; and (3) NDAA provisions that aim to accelerate the Department of Defense’s adoption of AI and Autonomous Systems and counter efforts by U.S. adversaries to subvert them. 

Future posts in this series will address NDAA provisions targeting China, supply chain and stockpile security, the revitalized Administrative False Claims Act, and Congress’s effort to mature the Office of Strategic Capital and leverage private investment to accelerate the development of critical technologies and strengthen the defense industrial base.  Subscribe to our blog here so that you do not miss these updates.

FY 2025 NDAA Overview

On December 23, 2025, President Biden signed the FY 2025 NDAA into law.  The FY 2025 NDAA authorizes $895.2 billion in funding for the Department of Defense (“DoD”) and Department of Energy national security programs—a $9 billion or 1 percent increase over 2024.  NDAA authorizations have traditionally served as a reliable indicator of congressional sentiment on final defense appropriations. 

FY 2025 marks the 64th consecutive year in which an NDAA has been enacted, reflecting its status as “must-pass” legislation.  As in prior years, the NDAA has been used as a legislative vehicle to incorporate other measures, including the FY 2025 Department of State and Intelligence Authorization Acts, as well as provisions related to the Departments of Justice, Homeland Security, and Veterans Affairs, among others.

Below are select provisions of interest to companies across industries that engage in U.S. Government contracting, including defense contractors, technology providers, life sciences firms, and commercial-item suppliers.Continue Reading President Biden signs the National Defense Authorization Act for Fiscal Year 2025

In early March, the EU released its first-ever European Defence Industrial Strategy (EDIS), accompanied by a proposed regulation establishing the European Defence Industry Programme (EDIP). The aim is to boost defence capabilities in Europe through greater and more efficient spending. In particular, the strategy seeks to reverse recent trends, whereby 78% of defence acquisitions by EU countries since Russia’s full-scale aggression against Ukraine were made with non-EU producers, with U.S. firms accounting for 63%. It also addresses recent concerns by the defence industry over ESG constraints on obtaining private financing.

The ultimate benchmark for success, as recounted by one EU foreign minister, is whether these measures will help deter Russia and other adversaries. Nonetheless, it reflects greater operational focus of the EU on defence and security issues, and what in practice the European Commission and other EU institutions can do to bolster capabilities in a policy area that will remain the primary prerogative of EU Member States.

Plugging Defence Gaps

Since the end of the Cold War, European defence has suffered from perennial underinvestment and lack of policy support for the defence industry. Whereas Europe collectively spent on defence over half of the U.S. totals in the early 1990s, it now spends about one-third compared to the United States—arguably at a time of much greater security threats to Europe compared to America. There are simply not enough soldiers, tanks, planes, ships, missiles, guns, and ammunition in Europe, nor domestic facilities to produce the necessary weapons systems and materiel. Moreover, EU countries have procured defence products at a national level, exacerbating fragmentation within the European market. This fragmentation has led to the creation of national industrial silos and numerous defence systems that often lack interoperability.Continue Reading Mobilizing Greater Defence Capabilities in Europe: the EU’s Defence Industrial Strategy

This year’s Munich Security Conference reemphasized the need for Europe to invest in greater defense capabilities and foster a regulatory environment that is conducive to building a defense and technological industrial base. In Munich, President Ursula von der Leyen committed to appointing a European Commissioner for Defence, if she is reselected later this year by the European Council and European Parliament. And the EU is also due to publish shortly a new defense industrial strategy, mirroring in part, the first-ever U.S. National Defense Industrial Strategy (NDIS) released earlier this year by the Department of Defense.

The NDIS, in turn, recognizes the need for a strong defense industry in both the U.S. and the EU, as well as other allies and partners across the globe, in order to strengthen supply chain resilience and ensure the production and delivery of critical defense supplies. And global leaders generally see the imperative of working together over the long-term to advance integrated deterrence policies and to strengthen and modernize defense industrial base ecosystems. We will continue tracking these geopolitical trends, which are likely to persist regardless of electoral outcomes in Europe or the United States.

These developments across both sides of the Atlantic follow on a number of significant new funding streams in Europe over the past couple of years, for instance:

  • The 2021 revision of the European Defense Fund Regulation allocated €8 billion for common research and development projects, meant to be spent during the 2021-2027 multi-annual financial framework (MFF).
  • As a direct response to Ukraine’s request for assistance with the supply of 155 mm-caliber artillery rounds, the EU adopted the 2023 Act in Support of Ammunition Production (ASAP), with a €500 million fund to scale up production of ammunition and missiles.
  • Most recently, the EU adopted the 2023 European Defense Industry Reinforcement through Common Procurement Act (EDIRPA), introduced a joint procurement fund of €300 million to facilitate Member States’ collective acquisition of defense products.
  • The European Peace Facility (EPF), an off-budget instrument, with an overall financial ceiling exceeding €12 billion, is primarily destined toward procurement of military material and large-scale financing of weapon supplies to allied third countries (including €6.1 billion for Ukraine).

Continue Reading Insights from the Munich Security Conference: Towards an Expanding U.S.-EU Defense Taxonomy?

On December 14, 2023, the U.S. Congress passed the National Defense Authorization Act for FY 2024 (NDAA), authorizing $886 billion in defense spending. Amid its numerous provisions, there is the concept of the “national technology and industrial base,” which now includes the United States, Canada, the United Kingdom, Australia, and New Zealand and could potentially serve as the basis for wider industrial cooperation with European and other global partners. This could provide useful synergies with ongoing efforts in Europe to galvanize defense production and help ensure an enduring competitive edge for the wider West over potential adversaries—within NATO and with global partners.

The Global “National Technology and Industrial Base”

The national technology and industrial base (NTIB) is defined in U.S. law as “the persons and organizations that are engaged in research, development, production, integration, services, or information technology activities” in national security and dual-use areas. First established in 1994, NTIB initially included only Canada in addition to the United States. In 2016, however, United Kingdom and Australia were added, followed by New Zealand in 2022. NTIB entities may receive preference for certain limited procurement actions and may be exempted from certain foreign ownership or control/influence requirements.

The logic behind this initial expansion was to foster industrial defense cooperation among the Five Eyes allies, which already had provisions for intelligence sharing potentially required for sophisticated military projects. And the expected benefits were to leverage economies of scale, promote innovation, and increase interoperability.

Given Russia’s large-scale war of aggression against Ukraine and the longer-term challenge from China, the NTIB could be expanded further to ensure that the wider West is able to produce the military materiel required to deter and confront any security challenges. The United States and its NATO Allies have already faced stockpile constraints in providing weapons supply to Ukraine to continue waging its defense. Now, the 2024 NDAA has added Israel and Taiwan to a program started to expedite delivery and replenishment of munitions to Ukraine, which will put further pressure on existing production. The NTIB could also serve as the fulcrum to leverage European defense initiatives in light of Russia’s war of aggression.

European Defense Initiatives

The European defense landscape has long been characterized by severe under-investment and fragmentation among Member States, with less than one-fifth of investments in defense programs conducted in cooperation. In 2009, the European Union expressed its willingness to facilitate joint procurement with the adoption of procurement rules for munitions, arms, and war material in the Defense Procurement Directive. However, implementation was lacking, and most procurement contracts were still awarded without an EU-wide tender.Continue Reading U.S. Defense Bill’s Implications for European and Global Partners

Following our recent overview of key topics to watch in the National Defense Authorization Act (“NDAA”) for Fiscal Year (“FY”) 2024, available here, we continue our coverage with a “deep dive” into NDAA provisions related to the People’s Republic of China (“China” or “PRC”) in each of the House and Senate bills.  DoD’s focus on strengthening U.S. deterrence and competitive positioning vis-à-vis China features prominently in the 2022 National Defense Strategy (“NDS”) and in recent national security discourse.  This focus is shared by the Select Committee on Strategic Competition Between the United States and the Chinese Communist Party (“Select Committee”), led by Chairman Mike Gallagher (R-WI) and Ranking Member Raja Krishnamoorthi (D-IL). 

It is no surprise, then, that House and Senate versions of the NDAA include hundreds of provisions—leveraging all elements of national power—intended to address what the NDS brands as China’s “pacing” challenge, including many grounded in Select Committee policy recommendations.  Because the NDAA is viewed as “must-pass” legislation, it has served in past years as a vehicle through which other bills not directly related to DoD are enacted in law.  In one respect, this year is no different—the Senate version of the NDAA incorporates both the Department of State and Intelligence 2024 Authorization bills, each of which includes provisions related to China. 

To get a flavor of the approach to China in this year’s NDAA, look no further than the “Ending China’s Developing Nation Status Act” in Section 1399L of the Senate bill, which would require U.S. opposition to granting China “developing nation” status in treaties under negotiation and by international organizations of which the U.S. and China are members, such as the World Trade Organization.  Classification as a “developing nation” affords China access to preferential loans and other economic benefits intended to increase trading opportunities, notwithstanding its current status as an upper-middle income country (as determined by the World Bank), and the world’s second largest economy, trailing only the U.S.  Not to be outdone, Section 155 of the House bill contains a provision mandating expedited deployment of advanced radars to track high-altitude balloons and other potential threats to the U.S., in direct response to the incident earlier this year in which a Chinese balloon flew across the U.S. before being shot down by the Air Force.

Given these provisions, and many more (some we discuss below), this year’s NDAA strikes us as different.  It incorporates many more China-related provisions and many of these would impose greater obligations on government contractors to limit their interactions with the PRC and entities affiliated with the PRC Government.  Whether the laundry list of China-related provisions in the current NDAA survive, and in what form, will be determined by the conference process currently underway.  But these provisions have the potential to impose significant near-term burdens on contractors—requiring them to assess their obligations and make adjustments to ensure compliance.  Indeed, these provisions may be far more disruptive than requirements imposed by prior year NDAA China provisions that contractors have navigated by reassessing supply chains and increasing due diligence.  All government contractors and suppliers to government contractors with any connection to China would be well advised to monitor how the NDAA conference approaches resolution of this legislation over the coming months.Continue Reading Not to Be Outpaced: NDAA Presents Measures Addressing China

On February 7, 2023, the House Committee on Armed Services (the “Committee”) held a hearing entitled “The Pressing Threat of the Chinese Communist Party to U.S. National Defense.” This hearing marked the Committee’s first in the 118th Congress and it focused on U.S. strategic competition with the Chinese Communist Party (“CCP”) of the People’s Republic of China (“PRC”). This overview is the first in a series of legislative updates we will provide on congressional oversight activities related to China throughout the Congress, including specific activities focused on trade controls, supply chain dependencies, and PRC-sourced telecommunications infrastructure in U.S. networks.

Admiral Harry Harris, USN (Ret.), former commander of U.S. Pacific Command, and Dr. Melanie Sisson, Foreign Policy Fellow at the Strobe Talbott Center for Security, Strategy, and Technology, appeared before the committee as witnesses. The substance and tenor of their testimony, reflected throughout the hearing from member statements, was bipartisan agreement that the PRC and the CCP pose a significant threat to the United States and its way of life.

Key members to watch this Congress, all of whom participated in the hearing, include, Representative Mike Gallagher (R-WI), HASC Member and Chairman of the House Select Committee on the Strategic Competition between the United States and the CCP, as well as Select Committee Members Rob Wittman (R-VA), Jim Banks (R-IN), Seth Moulton (D-MA), Andy Kim (D-NJ), Mikie Sherrill (D-NJ), and newly elected Carlos Gimenez (R-FL).

We expect these members will work together over the coming months to advance legislative measures in the defense authorization bill to address perceived threats posed by the CCP, particularly after its recent deployment of a surveillance balloon over the United States and military exercises near “Taiwan”.Continue Reading Public Policy Update:  Key Takeaways from the House Armed Services Committee Hearing on the Chinese Communist Party Threat to U.S. National Defense

Section 5949 of the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023 (“FY2023 NDAA”) contains two significant prohibitions regarding the procurement and use of semiconductor products and services from specific Chinese companies and other foreign countries of concern (the “Semiconductor Prohibitions”). Although many aspects of the prohibitions remain unclear, the legislation portends noteworthy obligations in the coming years for government contractors, their suppliers, and those who may be interested in entering into agreements with the United States.

A timeline of noteworthy events and requirements associated with the Semiconductor Prohibitions is available here.

I. The Prohibitions

A. Prohibition Text

The Semiconductor Prohibitions are divided into two subsections:

  1. Section 5949(a)(1)(A) (“Part A”) provides that the head of an executive agency may not “procure or obtain, or extend or renew a contract to procure or obtain, any electronic parts, products, or services that include covered semiconductor products or services.”
  2. Section 5949(a)(1)(B) (“Part B”) provides that the head of an executive agency may not “enter into a contract (or extend or renew a contract) with an entity to procure or obtain electronic parts or products that use any electronic parts or products that include covered semiconductor products or services.”

Continue Reading NDAA Prohibits Government Purchase and Use of Certain Semiconductors