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 | 14 min read | 03.13.26
AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems
On March 6, 2026, the General Services Administration (GSA) issued a significant proposed contract clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems (“Clause”), for inclusion in GSA Schedule solicitations and contracts for AI capabilities. The proposed clause would impose substantial new requirements related to AI sources, intellectual property rights, data use, change management, and performance standards. The Clause would also take precedence over any other contract terms (including commercial licensing terms) related to AI, including a Seller’s terms of sale and service to which the Government had previously agreed. GSA requests comments by March 20, 2026.
Client Alert | 3 min read | 03.12.26
DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy
Client Alert | 3 min read | 03.12.26
