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FAPIIS Information To Be Publicly Available

Client Alert | less than 1 min read | 08.03.10

On July 29, 2010, President Obama signed the supplemental appropriations bill which contained a provision amending the Clean Contracting Act of 2008 -- the legislation that gave rise to the Federal Awardee Performance and Integrity Information System ("FAPIIS"). As a result of the new language ("the Administrator shall post all such information, excluding past performance reviews, on a publicly available Internet website"), information in FAPIIS must be made available to the public, except for past performance reviews.

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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:...