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Non-Offeror Has Standing, and FAR Part 12 Commercial Item Restrictions Apply to GSA Schedule Procurements

Client Alert | less than 1 min read | 03.12.15

In CGI Fed. Inc. v. U.S.(Mar. 10, 2015), the Federal Circuit held that CGI was a "prospective offeror" and therefore had standing to pursue its preaward protest, despite the fact that CGI did not submit a proposal, which was due after CGI filed at GAO but before CGI filed at the CFC. The Federal Circuit also reversed the CFC on the merits, holding that the proscription in FAR part 12 of terms that are inconsistent with customary commercial practice does apply to solicitations for orders under FAR 8.4 (Federal Supply Schedule) contracts.

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Client Alert | 6 min read | 04.25.24

OMB Final Rule Rewrites the Uniform Guidance for Grants, Cooperative Agreements, and Other Federal Financial Assistance

On April 22, 2024, the Office of Management and Budget (OMB) issued a Final Rule significantly revising the Uniform Guidance for grants, cooperative agreements, and other federal financial assistance.  The Final Rule (titled “OMB Guidance for Federal Financial Assistance”), and OMB’s accompanying memorandum to agencies and reference guide, state that the revisions aim to streamline and clarify the grant rules and improve management, transparency, and oversight of federal financial assistance.  Agencies must implement the Final Rule by October 1, 2024; however, agencies may apply it to federal awards as early as June 21, 2024....