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CAS Pension Requirements In The Market Meltdown

Client Alert | less than 1 min read | 10.13.08

The drastic decline in the market value of the assets in defined-benefit pension plans is causing many contractors to review their options, including the possibility of partially or completely curtailing the accrual of future benefits under those plans. A complete curtailment of future benefits is a "segment closing" that would require adjustment of prior costs under CAS 413.50(c)(12) (producing a credit or refund to the Government if the plan is in surplus and a payment to the contractor if the plan is in deficit) and any decision to change future benefits may affect future costs, requiring timely disclosure in current negotiations under the Truth in Negotiations 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:...