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Changes to Acquisition Thresholds On the Way

Client Alert | 1 min read | 07.29.15

On July 2, 2015, the FAR Council published a final rule, effective October 1, 2015, increasing the micro-purchase base threshold to $3,500 (from $3,000), that for use of simplified acquisition procedures for acquisition of commercial items to $7 million (from $6.5 million), the cost or pricing data threshold and the Cost Accounting Standard threshold to $750,000 (from $700,000), the prime contractor subcontracting plan floor to $700,000 (from $650,000), and the threshold for reporting first-tier subcontract information (including executive compensation) to $30,000 (from $25,000). The simplified acquisition threshold ($150,000) and the construction threshold ($1.5 million) will remain at current levels.


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:...