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Preparing for Day-One Compliance with Fair Pay and Safe Workplaces

Client Alert | less than 1 min read | 09.22.16

On August 25, the Administration published the FAR final rule and Department of Labor final guidance implementing the "Fair Pay and Safe Workplaces" executive order, which imposes significant new compliance and reporting obligations on federal contractors. In a "feature comment" published in the Government Contractor, C&M attorneys provide an overview of the key provisions and discuss what contractors should be doing now to start preparing for day-one compliance with the new requirements that go into effect on October 25.

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:...