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CAS Board Adjusts Coverage Threshold

Client Alert | less than 1 min read | 06.14.07

The Cost Accounting Standards Board issued a final rule, effective June 14, 2007, adjusting the $500,000 threshold for contract coverage upward to $650,000 to be consistent with the threshold in the Truth in Negotiations Act (72 Fed. Reg. 32809). Apparently in response to comments from the Project on Government Oversight (POGO), the final rule (unlike the proposed rule published on December 15, 2005) does not increase the other CAS thresholds – such as the $7.5M “trigger” contract threshold and the $50M threshold for “full” CAS coverage and submission of a Disclosure Statement – because the CAS Board has determined that these are not “acquisition-related dollar thresholds” required to be adjusted for inflation under the FY05 Defense Authorization Act.

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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:...