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Comment Period for 'Fair Pay and Safe Workplaces' Extended Again

Client Alert | 1 min read | 08.07.15

In an August 3 letter to eight committee and subcommittee chairs, the FAR Council and the Department of Labor indicated that the comment period for the "Fair Pay Safe Workplaces" proposed FAR Rule and related DOL Guidance would be extended to August 26 (from the current date of August 11, 2015). On July 15, as previously discussed here, the chairs of the House committees of jurisdiction sent a letter to Labor Secretary Perez and OFPP Administrator Rung citing procedural and substantive flaws with the rulemaking (explained in more detail on our Government Contracts blog) and requesting that the agencies withdraw it, or, at a minimum, extend the public comment period an additional 90 days.


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:...