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The Latest Insights into Suspension and Debarment Activities Across the Federal Government

Client Alert | 1 min read | 02.05.21

The annual Interagency Suspension and Debarment Committee (ISDC) recently issued its annual report to Congress. The report, found here, contains details describing improvements to the federal suspension and debarment process and a summary of each agency’s suspension and debarment activities in Fiscal Year 2019. Throughout FY2019, the ISDC pursued a strengthened understanding and awareness of suspension and debarment activities across the federal acquisition and financial assistance communities, and continued to focus on modernizing/streamlining lead agency coordination. Otherwise, while the total numbers of referrals and suspensions increased in FY2019 compared to FY2018, proposed debarments and debarments continued to decline. In addition, the ISDC notes that from FY2018 to FY2019 agencies better utilized pre-notice letters to notify individuals or entities that the Suspension and Debarment Official (SDO) was considering SDO action, allowing the recipient an opportunity to respond before formal SDO action.

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:...