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OMB Proposes a 21st Century Federal Grants Regulatory Structure

Client Alert | less than 1 min read | 02.04.13

On February 1, 2013, OMB published a proposal to consolidate eight existing OMB circulars, establishing uniform standards for administrative requirements, cost principles, and audit requirements for all grants and cooperative agreements. While OMB's primary focus appears to be on consolidating existing federal financial participation regulations, OMB also included a "cross-walk" to the current Circular A-110 identifying the proposed policy changes and updates if the proposal were adopted.


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:...