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Bring Out Your Dead: GSA Instructs Agencies to Remove Null and Void FPSW

Client Alert | 1 min read | 06.27.17

On June 12, 2017, the General Services Administration issued a Class Deviation to remove the Fair Pay and Safe Workplaces Final Rule from the FAR after President Trump signed a joint resolution (P.L. 115-11) under the Congressional Review Act disapproving the final rule on March 27, 2017. Although most of the final rule’s requirements were put on hold in October when a U.S. District Court judge in Texas granted a preliminary injunction (discussion available here), paycheck transparency requirements at FAR clause 52.222-60 became effective on January 1, 2017. In this Class Deviation, GSA instructs agencies to not wait for formal rescission of the rule, but to take all necessary steps to comply with the joint resolution, including ensuring that new solicitations do not include FAR clause 52.222-60 and amending solicitations or modifying contracts to remove FAR clause 52.222-60 if included in either.

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Client Alert | 2 min read | 04.16.26

Federal Circuit Holds Challengers to CICA Stay Overrides Need Not Satisfy Four-Factor Injunctive Relief Test

In a significant decision for government contractors, on April 15, 2026, in Life Science Logistics, LLC v. United States, the U.S. Court of Appeals for the Federal Circuit held that bid protesters challenging an agency’s override of an automatic stay of contract performance under the Competition in Contracting Act (CICA) need not satisfy the demanding four-factor test traditionally required for preliminary injunctive relief.  In so doing, the Federal Circuit clarified that CICA stay override challenges need only demonstrate that the override decision was arbitrary and capricious—nothing more....