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IG Confirms Many Recovery Act Criminal Investigations

Client Alert | less than 1 min read | 11.03.11

In what should serve as a warning that use of Recovery Act funds continues to draw close scrutiny from federal watchdogs, in written testimony on November 2 before a House subcommittee, DoE Inspector General Friedman revealed that his office has initiated over 100 criminal investigations involving “various schemes, including the submission of false information [and] claims for unallowable or unauthorized expenses,” under the Recovery Act.   He also confirmed that his office has “ongoing and planned reviews” of Recovery Act funding and usage.

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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:...