Crossing The Threshold
Client Alert | 1 min read | 01.22.08
In a memorandum dated January 7, 2008, GSA's Senior Procurement Executive, David Drabkin, acknowledged that "currently there is no government-wide standard that addresses" whether the Trade Agreements Act (TAA) threshold (soon to rise to $194,000) applies at the order level or the contract value level for GSA multiple award contracts and is seeking to have all GSA Contracting Activities weigh in on the issue. Largely at the instigation of the IT industry which, back in the 1980s, wanted to be freed of counting component costs under the Buy American Act regulatory test for domestic end products, GSA has traditionally applied the TAA threshold to the total expected contract value for GSA Schedule contracts, but now given the Buy American Act exemption for commercial IT products contained in FAR 25.103(e), certain companies might well find it advantageous if the threshold were to be applied at the order level.
Contacts
Insights
Client Alert | 7 min read | 06.26.26
Federal Roundup: Updates for PBMs and Medicare Advantage Organizations
In June 2026, federal regulators and lawmakers continued their efforts to improve drug affordability through targeted reforms. These recent developments will primarily impact pharmaceutical manufacturers, managed care organizations, and pharmacy benefit managers (PBM) serving Medicare Part D program members. PBMs, Medicare Advantage organizations, and Part D sponsors should monitor these changes in the interest of maintaining compliance and providing input on regulatory proposals that may influence their business operations or compensation structures in the future.
Client Alert | 4 min read | 06.25.26
Twin Executive Orders Seek to Spur Quantum Leap in Technology and Cybersecurity
Client Alert | 7 min read | 06.24.26
Client Alert | 3 min read | 06.24.26

