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New OFCCP Regulations to go into Effect March 23, 2014

Client Alert | 1 min read | 09.26.13

The new Office of Federal Contract Compliance Programs (OFCCP) regulations governing affirmative action obligations towards protected veterans and individuals with disabilities, announced August 27th, were published in the Federal Register on September 24th. As such, the clock has started ticking on the 180 days until the revised regulations become effective. All contractors and subcontractors (collectively "contractors") must begin complying with the new obligations by March 23, 2014. The revised regulations contain significant changes to contractors' data collection, analysis and recordkeeping obligations. All contractors should start thinking now about how to best implement the new requirements by the March 23rd deadline. Please click here to see our prior alert from August 29 for a summary of the key changes that will be effective March 2014.


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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:...