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Annual ISDC Reporting

Client Alert | less than 1 min read | 11.07.19

The annual Interagency Suspension and Debarment Committee recently issued its annual report to Congress. The report, found here, contains details of the state of the federal suspension and debarment program for Fiscal Year 2018 (note the significant timelag). The report notes a focus on cybersecurity contractor compliance issues, and proposals to modernize/streamline lead agency coordination. Otherwise, total numbers of suspensions, proposed debarments, and debarments continued to decline year-over-year, while pre-notice interactions with contractors continued to comprise a significant portion of SDO offices’ dockets.

Insights

Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...