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CAS Coverage And Indirect Costs

Client Alert | 1 min read | 03.31.06

A previous Bullet Point addressed a recent decision, AM General LLC, in which the ASBCA decided that a contract awarded pursuant to a partial waiver of the Truth in Negotiations Act was nevertheless covered by the Cost Accounting Standards and adopted a “benefit” test for determining the homogeneity of indirect cost pools under CAS 418. In their article entitled “Practitioner's Comment: “Benefit” Test for CAS 418 Homogeneity,” published in the March 8, 2006, Thomson West The Government Contractor (http://www.crowell.com/pdf/newsroom/GovtContractor_March06.pdf), Terry Albertson and Linda Bruggeman discuss both the legal and practical problems with the Board's CAS 418 analysis as well as the legal issues presented by the CAS Board's lengthy delay in implementing the CAS exemptions in FASA and FARA.

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:...