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DHS Clamps Down On Lead System Integrators

Client Alert | less than 1 min read | 07.23.10

On July 15, 2010, the Department of Homeland Security issued an interim rule which mirrors a DoD rule, restricting contractors from acting as lead system integrators in the acquisition of DHS major systems if they have direct financial interests in the development or construction of individual systems or elements of any system that they integrate. Effective immediately, the rule contains several exceptions and also provides detailed definitions of lead system integrators and direct financial interests.

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:...