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Cleared Contractors Under the Gun As Insider Threat Program Deadline Approaches

Client Alert | less than 1 min read | 11.17.16

By November 30, 2016, contractors that have facility clearances through DoD's Defense Security Service (DSS) must have a written plan in place for implementing an insider threat program, a new requirement under the National Industrial Security Program Operating Manual. As the deadline looms, our team’s recent BNA article provides practical pointers to help contractors turn the high-level DSS guidance into a detailed but practical plan.

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:...